ORNL/EIS-189
                                               EPA-560/11-80-028
               Contract No. W-7405-eng-26
   PROCEEDINGS OF THE WORKSHOP ON
      SUBCHRONIC TOXICITY TESTING
                   Denver, Colorado
                    May 20-24, 1979

                       Edited by
                 Norbert Page, D.V.M.
              Daljit Sawhney, D.V.M., Ph.D.
          Office of Pesticides and Toxic Substances
           U.S. Environmental Protection Agency
                Washington, D.C. 20460

                         and

                    Michael G. Ryon
         Health and  Environmental Studies Program
       Information Center Complex/Information Division
              Oak Ridge National Laboratory
               Oak Ridge, Tennessee 37830
Work sponsored by the Office of Pesticides and Toxic Substances,
 U.S. Environmental Protection Agency, Washington, D.C., under
           Interagency Agreement No. 80-D-X0453
             Date Published: November 1980
         OAK RIDGE NATIONAL LABORATORY
             OAK RIDGE, TENNESSEE 37830
                     operated by
            UNION CARBIDE CORPORATION
                       for the
              DEPARTMENT OF ENERGY

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    At the time of publication, we were saddened to learn of the death of a workshop
contributor, Bernard McNamara. His scientific and personal advice will be missed by
those who worked with him on this and other projects.
                                    in

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                               CONTENTS

Tables	  vii

Preface	  ix

Keynote Address to the Workshop Participants	   1
  Warren R. Muir
Review of Current Activities in Test Standards Development	   5
  Norbert P. Page

Charge to the Workshop and the Individual Committees	  11
   Wayne M. Calbraith

Proceedings of the Workshop on Subchronic Toxicity Testing	15

1. Introduction	  15
   1.1  Scope	  15
   1.2  General Principles 	  15
   1.3  Objectives	  16

2. Relationship of Protocol Design to Chemical Characteristics	  16

3. Experimental Design	  19
   3.1  Exposure and Duration	  19
   3.2  Dose	  20
       3.2.1  Selection of Doses	  20
       3.2.2  Limitations of Maximum Levels	  20
   3.3  Species Selection	  21
   3.4  Number of Animals	  21
   3.5  Age of Animals	  21

4. Evaluation of Toxic Effects	  22
   4.1  Introduction	  22
   4.2  Clinical Observations and Evaluations	  23
       4.2.1  Physical	  23
       4.2.2  Health	  23
       4.2.3  Cardiovascular	  23
       4.2.4  Reproductive	  24
       4.2.5  Ocular	  24
       4.2.6  Behavioral	  24
       4.2.7  Neurological	  25
       4.2.8  Memory and Learning	  25

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                                    VI

   4.3 Clinical Laboratory Tests	  25
      4.3.1  Sampling Frequency	  26
      4.3.2  Hematologic Evaluations	  26
      4.3.3  Clinical Chemistry Evaluation 	  27
   4.4 Special Organ Evaluation	  28
   4.5 Unnalysis Evaluation	  29
   4.6 Pathology	  29
      4.6.1  Gross Examination 	  29
      4.6.2  Tissue Preservation	  30
      4.6.3  Justification of Selection of Tissues
             for Histopathological Examinations	  31
      4.6.4  Special Considerations	  32
      4.6.5  Central Nervous System	  33
   4.7 Analysis and Presentation of Test Results	  33
   4.8 Usefulness and Correlation of Test Results	  33

5.  Criteria for Data Extrapolations from One Route of
    Administration to Another	  35
   5.1 Introduction	  35
   5.2 Review of Data	  35
   5.3 Factors Affecting Extrapolation of Data Obtained by
       One Route of Exposure to Another	  40
   5.4 Assumptions and Criteria for Extrapolation	  41
   5.5 Retrospective Analysis and Extrapolation	  42
   5.6 Prospective Analysis and Extrapolation	  43
   5.7 Summary and Conclusions	  44

6.  Limitations of Acute and Subchronic Toxicity Studies	  44
   6.1 Introduction	  44
   6.2 Acute Toxicity 	  45
   6.3 Interpretation and Limitations of Acute Toxicity Studies	  45
   6.4 Subchronic Toxicity	  46
   6.5 Special Considerations 	  46
      6.5.1  Reproduction and Teratology 	  46
      6.5.2  Recovery	  46
      6.5.3  Pharmacokinetic and Metabolic Data	  47
   6.6 Dermal and Ocular Studies 	  47
   6.7 Conclusions	  48

7.  Unresolved Issues and Research Recommendations  	  48
   7.1 Unresolved Issues 	  48
   7.2 Research Recommendations  	  49

Appendix: Committees and Participants	  53
   Committees	  53
   Participants	  55

Bibliography	  59

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                                 TABLES

1.  Experimental design for recently proposed subchronic oral toxicity
    tests	   8
2.  Chemical and physical information	  17
3.  Acute toxicity information	  17
4.  General observations, clinical laboratory tests, and pathology
    examinations that may be used in subchronic toxicity studies	  34
5.  Acute toxicity of nefopam in three species	  36

6.  Effects of administration of compounds in which lethal toxicity is
    independent of (isoniazid), partially dependent on
    (DFP and pentobarbital), and  completely
    dependent on (procaine) route of administration	  37
7.  Comparative results of 90-d toxicity  studies in rats administered
    vinylidene chloride by drinking water or inhalation	  38
8.  Comparative toxicity in rats administered perchloroethylene
    by gavage or inhalation	  38
9.  Summary of results from two chronic toxicity studies
    in rats with 1,4-dioxane	  39
                                     Vll

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                                PREFACE

    This document is the product of a three-day workshop sponsored by the Office of
Pesticides and Toxic Substances of the Environmental Protection Agency (EPA) to
evaluate the subchronic toxicity test and its role in chemical assessments mandated
under the Toxic Substances Control Act (TSCA). The Health and Environmental
Studies Program of the Oak Ridge National Laboratory (ORNL) had the responsibility
for the coordination of the workshop and the preparation of the resulting proceedings.
The participants, selected to achieve  a  balance of industrial,  academic, and
governmental viewpoints, were provided with a review of the pertinent literature
prepared by ORNL. Because many of the topics scheduled for discussion had limited
support in available literature, much of the document represents the results of the
committees' discussions, analyses, and recommendations.
    The workshop was divided into five  committees, each with  a specific area for
discussion.  The proceedings of the workshop are  a  consolidation of the five
committee drafts into one report, thereby enhancing the cohesiveness of the rationale
and avoiding repetition in the discussions.
    In preparing this report, both during and after the workshop,  several individuals
were especially helpful. Dr. Witschi of the ORNL Biology Division advised the ORNL
staff on technical matters and was responsible, in large part, for the initial organization
of the workshop and steering committee. The steering committee members, Drs.
Galbraith, Gibson, Oehme, Peck, Pfitzer, Page, Sawhney, and Terhaar, contributed
much time and effort to the refinement and completion of this project. The success of
the enterprise was also due to the  guidance provided by the EPA Deputy Assistant
Administrator, Dr. Muir, and the EPA Senior Medical Advisor, Dr. Seifter. Foremost
among the reasons for the success of the workshop, however, was the enthusiastic
and altruistic attitudes of the  participants,  who, despite differences in scientific
opinion, maintained friendly, open-minded discussions.
    Because the EPA desired a general evaluation of subchronic toxicity testing, this
workshop addressed the major issues. No  attempt was made to cover every aspect of
assessment. That some issues are not addressed in the report does not mean they are
less significant. The committees identified areas in which research is needed and
problems of test design unresolved during the workshop. Recommendations based
on these findings were an important product of the committee discussions.
                                     IX

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 KEYNOTE ADDRESS
 TO THE
 WORKSHOP PARTICIPANTS

 WARREN R. MUIR
 U.S. Environmental Protection Agency

     I would like to welcome all of you here to Denver and thank you for participating
 in this workshop. It is an undertaking that we at the Office of Toxic Substances and
 the Environmental Protection Agency (EPA) feel to be very important. We certainly
 appreciate that you are attending and helping us with this effort.
     I am Warren Muir and I head the Office of Testing and Evaluation, which is one of
 the three offices set up to implement the Toxic Substances Control Act (TSCA) in
 EPA. As most of you are aware, TSCA was passed in 1976 as a particularly important
 new piece of legislation dealing with chemical substances and their hazards. Unlike
 the 15 or so preceding acts, which also address regulation of chemical substances,
 TSCA is unique in its authorities to generate health, environmental, and other
 chemical information from the industry  which  manufactures  or  proposes to
 manufacture chemicals. Therefore,  in our efforts to support our  direct regulatory
 controls and to increase our understanding of the nature of the chemicals before they
 enter our environment, we are especially emphasizing the TSCA aspects of reporting,
 record keeping, information systems, testing, and evaluation of information.
     The  Office  of  Testing and Evaluation,  the  scientific office  of the three
 implementing offices, is responsible for  the definition of testing in terms of both
 requirements and guidelines. The Office is also responsible for compiling information
 available  to the EPA (including information to be generated under  this testing),
 analyzing it, and evaluating it to formulate risk assessments on chemicals.
     With respect to testing, there are two provisions that are applicable and in which
 we are heavily involved. One is Section 4 of TSCA, a section of the act which allows
 EPA to specify both test standards and chemicals to which the test standards would
apply. It  basically requires either processors or manufacturers or  both to conduct
testing on high priority chemicals. These are chemicals which the EPA may define as
posing an unreasonable risk or which are produced in substantial quantities with
either substantial releases to the environment or substantial risk for human exposure.
    With respect to Section  4, the first  set  of  test standards, which include
oncogenicity, chronic toxicity, and the combined oncogenicity and chronic toxicity
protocols, were published in proposed form in the Federal Register about two weeks
ago [9  May 1979]. Also published were the Good Laboratory Practices that were
patterned after the proposed  Food and Drug Administration's Good Laboratory

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Practices for nonclinical health effects studies.  With respect to the topic for this
meeting, subchronic toxicity testing, we intend to propose, in a couple of months,
subchronic toxicity test protocols along with acute toxicity, mutagenicity, reproduc-
tion, and teratology tests.  The proposal,  which will be published  in the Federal
Register, will be a reproposal of the test protocols that have been previously proposed
by the Office of Pesticides Programs under Section 3 of their pesticide guidelines for
the Federal Insecticide, Fungicide, and Rodenticide Act. We are proposing those
standards in an effort to focus upon the various issues associated with those test
protocols and to allow us the time to get together with the Office of Pesticides so that
in going final with our test  standards and  test guidelines, that office and ours can
merge efforts to come up with protocols that are identical to the maximum extent
allowable under the two different laws. In addition, we are also working with the
Interagency Regulatory  Liaison  Group,  to  make sure that there is  maximum
consistency not only across  EPA offices in defining acceptable testing methodologies,
but also across the  federal regulatory agencies.
    The other section of TSCA in which testing comes into play is Section 5, which
applies to new chemical substances, new chemical substances being those that are
not contained on the TSCA chemical inventory of all existing chemicals in commercial
use. The inventory has been published. It is being distributed now, and Federal
Register notices are going out indicating the official date of the inventory publication to
be June 1. On July 1, thirty days after publication, the premanufacturing notification
review process will be initiated.
    The premanufacture notification review (mandated under Section 5) will consist
of evaluating certain information  about the chemical's identity, use, production,
exposure, etc., and also all available health and safety studies on the material that is
being proposed for manufacture.  We do not generally have the authority under
Section 5 to require testing.  However, testing of new chemicals can be required if they
fall under Section 4, in particular, if they fall in categories of chemicals that might be
specified under Section 4. Also, under Section 5(e), the EPA has the authority to issue
an order to limit production, distribution, or use as  necessary if there is insufficient
information provided to the EPA to enable it to determine whether the chemical poses
an unreasonable risk, or if the EPA can demonstrate that the chemical may pose an
unreasonable risk,  or if the chemical is produced in  substantial quantities with
substantial  release or exposure.
    Because of the Section 5(e) provision  in which the EPA may limit exposure or
production in some fashion and because of concerns by industry and others  as to
what the EPA expects and will be satisfied with, we have contemplated coming forth
with Section 5 testing guidance, which would describe the type  of testing and the
testing scheme or approach we would most like to see performed. To date, this has
been a very controversial area, as I am sure many of you are well aware. We have had a
number of open public meetings and have decided to move along fairly deliberately in
this area before we  propose the document. As a result we decided that rather than
publish a formal proposal, we would first publish a discussion document which laid out
the various alternative approaches available to the EPA for testing and then suggest a
menu of tests we thought might be appropriate to incorporate into a future testing
guidance. Also, we want to solicit as much public comment as possible regarding both

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 the scientific merits of the tests and the various arguments, scientific and other, which
 might impinge upon the choice the EPA would make among the various available
 alternative testing approaches. That discussion document was published March 16 in
 the Federal Register. It is still open for comment, and we are getting a large response.
     With respect to assessments, our office is involved in four different types. One is
 under the chemical substances premanufacture notification process. Another is a
 review of chemicals to see if they meet the Section 4 criteria for testing, and two others
 deal with existing chemicals. These last two include our comprehensive assessment
 process and a priority problem assessment, the priority problem assessment being a
 subset of comprehensive assessment and  a  faster  track. These latter two are
 multistaged  assessments of existing chemical substances, multistaged primarily so
 that we can take the limited amount of resources available in our program and target
 them as efficiently as possible on the highest priority problem chemicals. This focuses
 our  limited energies on those chemicals of greatest importance. Therefore, we do
 basically a quick and dirty analysis on a very large number of chemicals and then
 narrow down to what in the last analysis are many fewer chemicals.
     In the later stages of chemical assessment, we go through all the relevant
 scientific information in an effort to pull together as good a risk evaluation as possible
 and  use  this evaluation to base actions or potential actions under TSCA or other
 regulatory statutes. Because of  both  our  testing authorities and our assessment
 activities, we are particularly interested in evaluating the state of the art of various
 testing approaches, in particular today, to focus upon subchronic toxicity testing. We
 are very interested in the state of the art of this type of testing method in the context of
 TSCA authorities and of our ability to use it in terms of both our testing schemes and
 our evaluations of  information.
     We are particularly interested in this workshop and addressing questions such as
 proper protocol designs and the extent to which protocol design should be very
 specific or more general. We recognize that under Section 4 of TSCA, the EPA has to
 specify beforehand what  testing should be done and is not able  to turn away
 inadequate studies later, as long as the studies meet the required specifications. In this
 regard,  the  EPA is unlike the  Food  and  Drug Administration and the Office of
 Pesticides Programs,  which register materials only  after acceptable studies are
 performed.
     Further, we are interested in any judgments the workshop can make with respect
 to the relevance of the subchronic toxicity test results for risk assessments. We are
 also  interested in the  judgments of this particular group with respect  to the
 relationship of subchronic toxicity tests to other types of tests, such as acute tests or
 chronic tests in an evaluation scheme. For example, Dr. Seifter, my Medical Science
Advisor, is of the opinion that perhaps a subchronic toxicity test does not have a place
in a TSCA evaluation scheme at all, tha.t we may be able to substitute a shorter test of
 14 or 28 d with considerably more information on metabolism, biochemistry, etc., and
 then, depending upon the results, follow directly with a chronic test. We would be
 interested in the views of this group on this idea and  others.
     I presume  that there will be ample opportunity to ventilate that particular
proposal. We are,  therefore, interested in these types of activities, and you can
understand why this particular workshop is so important to our office. Because of our

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interest we asked the Oak Ridge National Laboratory to assist us in establishing this
workshop, and we are very pleased with the group we have been able to assemble
here to meet this week. We deeply appreciate the sacrifices each and everyone of you
has made in your busy schedule to come out here, roll up your sleeves, and work with
us on this agenda. Thank you.

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REVIEW OF
CURRENT ACTIVITIES IN
TEST STANDARDS DEVELOPMENT

NORBERT P. PAGE
U.S. Environmental Protection Agency

    During  the  last few years,  increased legislative responsibilities have  been
assigned to government agencies in both the U.S. and abroad to better evaluate
environmental chemicals for their potential toxic hazards. Safety assessment has
been  routine in the pharmaceutical industry for years.  Safety testing of food
additives and pesticides and, to a lesser extent, industrial chemicals has also been
conducted. Now virtually all chemical manufacturers are responsible for developing
data to demonstrate the toxic potential  of  their  products, regardless of their
products' intended uses.
    Many laws have been passed which  require that the government  agencies
develop standards or guidelines by which testing must be conducted. With these
new demands, a flurry of activity has taken place both in the U.S. and abroad in
the test standards or guidelines area. Dr. Muir has already spoken to the specific
needs  of the EPA in fulfilling its mandates under the Toxic Substances Control
Act.
    It  is my  intent  in this presentation to demonstrate how the EPA  relates to
other ongoing activities in the testing area. Four different acts within the purview of
the EPA alone require  the testing of chemicals and the  development  of testing
guidelines. These are the Toxic Substances Control Act (TSCA), the Federal
Insecticide, Fungicide,  and  Rodenticide  Act (FIFRA),  the Clean Air Act  as
amended in  1977  (fuels and fuel additives), and the Resources Conservation and
Recovery Act (hazardous wastes).
    Among  the  other  regulatory agencies,  the  Consumer  Product Safety
Commission (CPSC), through the National Academy of Sciences (NAS), revised
its procedures for toxicity testing of household products  (NAS  1977). This was
completed about two years ago. The Food and Drug Administration (FDA) is now
engaged in a cyclic review of approximately 2100 direct food additives. They are
developing procedures  for  toxicity assessment including identification of test
procedures.  The Food  Safety Council (1978) has also produced a series of test
procedures.  In  an  FDA-related  activity, the  Pharmaceutical  Manufacturing
Association has drafted its Preclinical  Guidelines for Assessment of Drug and
Medical Device Safety in animals.

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    On the  international scene, several  foreign countries, the World Health
Organization (WHO),  the European Economic  Commission (EEC),  and the
Organization for Economic Cooperation and Development (OECD)  have been
producing test guidelines. I am sure I left out a few other ongoing efforts. Many of
you have participated in these guideline activities.
    One could pick from any number of protocols, and having such a  wide range
of choices may at first  seem to be an advantage.  On the other hand, conflicting
methods may be required of the manufacturer of a product—especially where
there is more than  one use—to satisfy  the requirements of several agencies  or
countries.

                        Attempts at Harmonization

    What is being  done to harmonize  guidelines? Harmonize—that  is the new
word about  town  that sounds better  than,  but means about the same as,
standardization.
    Within the EPA, the Office of Pesticides Programs  and the Office of Toxic
Substances have joined together to develop a common  set of guidelines. Those
implementing  the Clean Air Act in  the testing  of  fuels and fuel  additives are
committed to using  the TSCA/FIFRA guidelines rather than producing their own.
Thus, the EPA will basically have a single set of toxicity testing guidelines.
    Within the federal bureaucracy, the regulatory agencies have banded together
to come up with consistent and cooperative regulatory actions. To achieve this,
the Interagency Regulatory Liaison Group (IRLG) was formed. One work group
was  chartered specifically for  toxicity  guidelines and  standards.  Five federal
regulatory agencies  participate: EPA, FDA, CPSC, the Occupational  Safety and
Health  Administration,  and the U.S.  Department of  Agriculture.  Dr.  Victor
Morgenroth (FDA),  the chairman, is participating in  this  conference. When IRLG
develops final guidelines, the agencies will adopt them.
    As far  as the International circuit is  concerned, the  U.S.  is  an active
participant in both the WHO and OECD programs. Of the two, the  OECD will
likely carry the most clout. Participating countries will likely accept the methods
developed and incorporate them into their chemical control laws.

                 Status of Activities/Concept of Progress

    Last August under FIFRA, the EPA proposed  pesticide registration guidelines
for the major health effects. On May 9, the EPA proposed chronic standards and
Good Laboratory Practices (GLPs) under TSCA. It is expected that in July  or
August most of the remaining TSCA standards for health effects testing will  be
proposed. These will be essentially the same as the FIFRA guidelines.  By the end
of the year  or in early 1980, joint TSCA/FIFRA  guidelines should be ready for
finalization in the Code of Federal Regulations. The IRLG is also participating with
the EPA in reviewing public comments and revising the proposed guidelines.
    The IRLG will soon propose a series  of guidelines  for acute effects and
teratogenicity. It is  expected that subchronic guidelines  will be ready for agency
reviews by late summer and those for chronic tests, by fall.

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    The OECD  has formed several  groups of experts to prepare universally
acceptable guidelines. The U.S. has the lead in establishing guidelines for chronic
effects  and  GLPs,  the British,  for  short-term  effects,  and  Sweden,  for
step-systems.  Other  groups  are  also working  in  ecotoxicity,  biodegradation,
bioaccumulation,  etc. Proposed guidelines are now prepared  for  eye  and skin
irritation, acute and subacute toxicity, and teratology. As with the IRLG, it will be
summer before the OECD has drafted  a subchronic test protocol.

         Review of Recently Proposed Subchronic Toxicity Tests

    Table 1 lists the basic experimental design for four of the recent activities that I
mentioned. There are no great surprises here, as the designs are similar to those that
have  been in use for several years. They all call for a fairly detailed clinical and
pathological examination, including microscopic  examinations. There are some
differences in organs to be weighed, tissues to be examined, etc. These differences
should be reviewed by the appropriate work groups. Whereas there is fair consistency
in certain design aspects, other areas are controversial (e.g., duration, species). The
FDA's draft for food additives testing is very similar to that for the IRLG shown in
Table 1.
    In addition to the 90-d oral subchronic tests, other subacute or subchronic tests
have recently been proposed. The FIFRA guidelines provide a separate protocol for a
90-d subchronic inhalation toxicity test.  The basic design is similar to that presented
for the 90-d oral test, except that only the rat is required, and the number per group is
only 10 instead of 20. The remainder of  the design is virtually the same but with
increased clinical and pathology examination of the respiratory system. The IRLG has
not yet prepared guidelines for a subchronic test by the inhalation route.
    The proposed FIFRA guidelines and the IRLG  guidelines also include dermal
toxicity tests of 90-d durations. In both, albino rabbits are the species of choice. Eight
to ten young adults of both sexes are used for each of three dose levels plus controls.
The highest dose is to be selected to produce toxic effects but not cause excessive
mortality (over  10%). The lowest dose should be a no-observed-effect level.
    The FIFRA proposed guidelines provide a 21-d dermal toxicity test for products
whose pesticidal use is likely to result in repeated human  skin contact. This is not
needed when a 90-d dermal toxicity test is performed.  Except for duration, the
protocol is the same  as for the 90-d dermal test.
    The FIFRA proposed  guidelines  require a delayed neurotoxicity test with
mammals if neurotoxicity was observed with acute tests. The species to be tested is
that which demonstrated the neurotoxicity signs. Both sexes are to  be used for
mammals, whereas only the  female domestic chicken is used. At least three dose
levels each with 10 animals of each sex are employed with exposure for a 90-d period.
The highest dose is one that induces toxic  effects, whereas the  lowest should not
induce any deleterious effect. Observations for behavioral abnormalities, including
locomotor activity, are called for, along with very detailed and complete pathological
examination of the central nervous system and peripheral nerves.

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                            The 28-d Toxicity Test

     The FDA is proposing a 28-d toxicity test that they refer to as a range-finding oral
toxicity study. It is intended to determine the target organs and find a range of doses
for subchronic or chronic tests. It is similar to the 90-d IRLG oral subchronic test,
except for a 28-d exposure and fewer animals per group (i.e., 10 rats instead of 20 and
2 dogs instead of  4 or 6).
     The  OECD/EEC has  also proposed a  28-d test using the rat only, but it is
otherwise like the FDA test. The 28-d test is to be used in a step-sequence system. The
concept of the step-sequence scheme is to determine the tests to be performed based
upon the potential for exposure and effects. The current sequence for testing new
chemicals as proposed by the EEC and OECD is as follows: for less than one ton, no
tests are needed. For all chemicals produced in quantities of one ton or more, a series
consisting of acute toxicity tests, a battery of two or three mutagenicity tests, and the
28-d test are required. For those chemicals to be produced in quantities greater than
10 tons, more testing is needed (e.g., fertility test, teratology tests in one species, more
mutagenicity tests, and a 90-d subchronic test). At production of 1000 tons, the ante
goes up even further in that chronic tests and pharmacokinetic studies would be
undertaken.
     I hope from this quick review you can see the role that the subchronic test will
play in  the U.S. and international  plans for safety assessment of chemicals. The
subchronic test, more than any other, plays a pivotal or key role in virtually all safety
assessment schemes. Much of the driving force behind protocol design by OECD and
TSCA for new chemicals is that of economics. We recognize  that testing costs can
stifle the introduction of new chemicals and that inconsistent testing requirements can
create international trade barriers. These are both issues of concern to EPA in its
implementation of TSCA.  This workshop needs  to  examine  the  trade-offs in
sensitivity and usefulness of the subchronic test if we reduce requirements (e.g., 2
species to one, 90 d to 28 or less, reducing clinical or pathology requirements, etc.).
We need solid data to predict the consequences of such modifications in test design.

                                 REFERENCES
    Federal Register. 1978.  Proposed  Guidelines for Registering  Pesticides  in the  U S. Hazard
Evaluation  Humans and Domestic Animals  U.S. Environmental Protection Agency (40 CFR 163).
43(163) 37336-37403
    Food Safety Council  1978.  Subchronic Toxicity  Studies. In. Proposed System for Food Safety
Assessment Columbia, Md pp. 83-92.
    Interagency Regulatory Liaison Group. 1979a IRLG  Guidelines for Subchronic Ingestion Testing
(unpublished)
    Interagency Regulatory Liaison Group. 1979b. IRLG Guidelines for Subchronic Dermal Toxicity
Tests (unpublished).
    National Academy of Sciences Committee for the Revision of NAS Publ.  1138  1977 Principles
and Procedures for Evaluating the Toxicity of Household Substances NAS, Washington, D.C. 130 pp.
    Page, N P 1977  Concepts of a Bioassay Program. In: Environmental Carcmogenesis. H. Kraybill
and M. Mehlman, eds Hemisphere Publishers Inc , Washington, D C pp. 87-171
    Sontag, J. M., N P Page,  and U  Saffiotti  1976. Guidelines for Carcinogen Bioassay in Small
Rodents Department  of Health, Education, and Welfare Publ. No. (N1H) 76-801. 65 pp.
    World Health Organization 1978. Acute, Subacute, and Chronic Toxicity Tests In- Principles and
Methods for Evaluating the Toxicity of Chemicals Part 1. Environmental Health Criteria 6. Geneva, pp.
95-115

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CHARGE TO THE WORKSHOP
AND THE INDIVIDUAL COMMITTEES

WAYNE M. GALBRAITH
U.S. Environmental Protection Agency

    A subchronic toxicity study can be defined as qualitative and quantitative
evaluation  of the  physiological and  pathological  changes in  the  rodent  and/or
nonrodent resulting from regularly repeated exposure to a chemical over a period of
one to three months.
    It is generally recognized that toxicity resulting from acute chemical exposure
and that resulting from subchronic and/or chronic exposure may differ. The results
of acute studies may not be  adequate to predict toxicity which results from
repeated low-dose chemical exposure. Therefore,  the subchronic toxicity study is
fundamental  in determining the toxicity profile of chemical substances to which
repeated or continuous human exposure can occur.
    It is the  objective of this workshop to summarize the various factors which
should be incorporated into the experimental design of an "end result"1 subchronic
toxicity evaluation and to examine  the scientific basis for these factors. The
ultimate objective of the workshop is  to provide the rationale for cost-effective and
scientifically sound subchronic toxicity testing procedures.
    The committees should summarize the historical data bases which justify the
inclusion of the various  parameters in a subchronic study. When it is  determined
that expert opinion cannot be  substantiated by an adequate data base, research
recommendations  should  be  made.  In the course  of your deliberations, all
committees  are also requested  to  devote attention to defining the  technical
terminology used in the committee documents.
    It is not the objective of this workshop to duplicate what has been accomplished
in a number of reviews and proposed test systems published in recent years (National
Academy of  Sciences 1975, 1977; World Health  Organization 1978; Food Safety
Council 1978; U.S. Department of Health, Education, and Welfare 1971; Association
of Food and Drug  Officials  of  the  United States 1959). Nevertheless, some
duplications of previous efforts  are unavoidable and  desirable to the end that the
workshop product is  comprehensive. When  appropriate, the committees  are
encouraged to summarize and update pertinent information in previous reviews.
   'The term "end result" is intended to distinguish a study designed as the terminal toxicologic
evaluation of the toxic effects of a chemical from a subchronic study used to determine dose levels for a
chronic study.

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                                     12

    The workshop should  focus  on the  testing of chemicals covered by the
Federal Insecticide, Fungicide, and  Rodenticide Act and the Toxic Substances
Control Act. The workshop is divided into  committees which will address five
general topics pertinent to subchronic toxicity evaluation.
    The first committee will discuss general experimental design. Considerations
such  as minimum test duration,- dosage,  number of animals, test species, and
animal age at time of chemical exposure will be evaluated by this group. For
example,  many  scientists  have difficulty  agreeing  with  the requirement  of  a
maximum permitted mortality in the high dose group in a subchronic study. Is this
requirement justified? Would it be preferable to employ 10-15 rats per sex/dose
group and have  5 or  6 dose levels rather than 3  dose levels with 20 rats per
sex/dose  group? What are  the  advantages and disadvantages of each  study
design?
    The second  committee  will  review parameters evaluated in a subchronic
toxicity study. This includes general observations,  clinical laboratory  tests, and
pathologic evaluations. A suggested minimum base set of general observations for
rodent and nonrodent subchronic  toxicity studies should be developed. It is also
requested that the second committee address the desired frequency of chemistry
and hematologic evaluation.
    It has been suggested to the Agency that total serum protein, serum albumin,
and serum protein electrophoresis are a better monitor of liver toxicity than serum
glutamic oxaloacetic transaminase and  serum glutamic pyruvic transaminase.  Is
there an adequate data base  substantiating this statement? Are cholesterol and
uric  acid  determinations justified  in  rodent  and nonrodent  subchronic toxicity
studies? Should sperm motility be evaluated in control and treatment groups at the
time of sacrifice?  Are there other tests not routinely performed which should be?
Are there special techniques,  histochemical or other, which can be employed to
increase the sensitivity of a subchronic toxicity study for detecting neurotoxicity?
What comprises  an adequate  neurologic examination in the  rat and dog  in  a
subchronic toxicity study?
    It is recognized that  no toxicity testing protocol will be adequate in every
experiment. For  this reason the third committee has been asked to  evaluate the
relationship of protocol  design  to  chemical  class and  characteristics.  What
observations, clinical laboratory tests, and/or pathologic techniques not routinely
made should be included in protocol on the basis of  chemical class? That is, what
modifications  in  protocol  design   should  be  made  on  the  basis of the
physical-chemical properties of the test substance? What are the hazards or pitfalls
associated with the subchronic evaluation of specific chemical classes? Examples
that readily come to mind are the need to evaluate  methemoglobin when testing
nitrates and nitrites, the need for a cholinesterase activity  evaluation when testing
an organic phosphate or carbamate pesticide, and the potential aspiration hazard
when conducting an oral-dosing study with certain hydrocarbons.
    The  fourth  committee  will  evaluate  the  criteria  to  be  employed for
extrapolations from one route (i.e.,  oral, dermal, inhalation)  to another route  of
administration. Because the cost of a subchronic inhalation study is at  least  twice
that of a comparable oral-dosing study, it  is imperative to know when inhalation

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                                       13

studies should be performed and when studies employing other dosing routes will
be  adequate. In this regard, what role should the results of acute inhalation and
oral-dosing studies play in determining the need for subchronic studies using more
than  one route of administration? What  criteria will be used to extrapolate  from
oral-dosing studies to inhalation studies? What assumptions must be made? What
other studies, if any, must complement oral subchronic studies in order to make an
extrapolation?
    The fifth committee will evaluate the  limitations of subchronic toxicity studies.
What subchronic findings should trigger the requirement for a  chronic study?
What manifestations of toxicity are not likely to be observed in a subchronic study
but may be found in a chronic study? How much information regarding maximum
tolerance  levels for  humans  can  be obtained from a subchronic  study?  Is
comparative metabolism  the key factor in evaluating a  toxicity profile of the same
chemical in the rodent and nonrodent? If  this  is the case, is it possible to eliminate
the need  for a  complete study in  one  species  when it  is  determined that the
adsorption,  distribution,  metabolism, and elimination pattern is  similar for the
rodent  and nonrodent? How useful are the results of acute toxicology studies for
determining  if a metabolic difference exists in  the  rodent and nonrodent?
    Other potential topics for consideration by this committee are the desirability
of  performing combination  tests (e.g., subchronic  and teratology in  the same
study), dosage extrapolation from laboratory animals to man, and results of acute
toxicity which should trigger subchronic studies.
    By Thursday morning each committee should have prepared draft documents
which address  the  assigned topics.  The document may  also contain research
recommendations and discussions of additional problems  which  the participants
consider  pertinent  to  subchronic  toxicity testing. Of course,  because  of  time
constraints, it is recognized that all of the suggested topics may not be discussed.
    Following the workshop, each participant is requested to make  additions,
corrections,  or other  changes  in  his  or her committee's draft  document and
forward them to the appropriate chairman.

                                REFERENCES

    Association of Food and Drug Officials of the United States,  1959 Appraisal of the Safety  of
Chemicals in Foods, Drugs, and Cosmetics. 106 pp.
    Food Safety Council. 1978. Proposed System for Food Safety Assessment Columbia, Md. 136 pp
    National Academy of Sciences 1975 Principles for Evaluating Chemicals in the Environment.
National Academy of Sciences.  Washington, D.C 454 pp.
    National Academy of Sciences. 1977 Committee for the Revision of NAS Publ. 1138  Principles
and Procedures for Evaluating the Toxicity of Household  Substances NAS, Washington, D C 130 pp.
    U.S. Department of Health,  Education, and  Welfare.  1971  Food and Drug  Administration
Introduction to Total Drug Quality  U.S. Government Printing Office, Washington, D.C  No 1712-0020.
    World Health Organization. 1978. Acute, Subacute, and Chronic Toxicity Tests In Principles and
Methods for Evaluating the Toxicity of Chemicals Part 1  Environmental Health Criteria 6. Geneva pp
95-115.

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           PROCEEDINGS OF  THE WORKSHOP ON
              SUBCHRONIC TOXICITY TESTING

                          1. INTRODUCTION

                                1.1 Scope

    Under the Toxic Substances Control Act (TSCA) and the Federal Insecticide,
Fungicide, and Rodenticide  Act (FIFRA), the Environmental Protection Agency
(EPA) is required to provide  standards or guidelines for the testing of chemicals for
health and environmental effects. The EPA is also required to perform hazard or risk
assessments for selected existing chemicals in the environment as well as for all new
chemicals to be manufactured in the United States or to be imported. In addition to
EPA's legislative requirements, other U.S. federal regulatory agencies and other
countries have similar requirements to provide testing guidelines or guidance. The
EPA has joined with other U.S. agencies in forming the Interagency Regulatory
Liaison Group (IRLG)  and with other countries in the Organization of Economic
Cooperation and Development (OECD). Both the IRLG and the OECD have work
groups to design testing procedures for the development of data for risk assessment
of chemicals.
    The  subchronic study is a key test in assessing the relative safety of chemicals
to which repeated or continuous exposure to humans can occur. This test is likely to
be a fundamental  part of any  guidelines for the toxicity  testing of new chemicals
entering the  market.

                          1.2 General Principles
    Subchronic toxicity procedures are designed to determine the adverse effects
that may occur with repeated  exposure over a part of the average life span of an
experimental animal. The  boundary between the subchronic and chronic dosing
regimes is often taken  as 10%  of an animal's lifetime; thus subchronic will include
dosing regimes described as subacute (Organization for Economic Cooperation and
Development 1979). Subchronic studies often involve multiple dosage levels, some of
which may exaggerate by significant multiples  the  anticipated levels of human
exposure. Testing procedures normally include the routes of exposure expected for
man. Usually one, two, or more animal species are exposed to the chemical for a
period of 90 d to evaluate the potential hazard. In the United States, one rodent (the
rat) and one nonrodent species (the dog) are generally employed as the two species. In
some other countries,  the mouse, rather than a  nonrodent,  is used as a second
species. The selection  of animal species for  subchronic  studies should consider,
                                    15

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                                     16

whenever possible, whether the test species' metabolic handling of the chemical or its
analogs is similar to that of humans. Exposure levels used in the studies are lower than
those in  the acute toxicity procedures, and lethality is  usually not an end point.
Instead,  by  including many  types of  observations (behavioral,  growth  rate,
hematological, biochemical, and functional) and extensive pathological evaluations,
more subtle types of adverse effects can be detected.
    Man may be exposed for the majority of his lifetime to low levels of a wide variety
of chemicals. Usually the degree of exposure is insufficient to produce overt signs of
toxicity; thus cause-effect relationships cannot be easily established. Epidemiological
studies may assist in this respect, but because man is often exposed simultaneously to
several chemicals, it is  difficult to  establish unequivocally the degree of hazard
associated with any one chemical.

                               1.3 Objectives

    For purposes of this report, the subchronic toxicity study is defined as an "end
result" study, that is, it will be the only long-term study available to the regulatory
agency responsible for making decisions about the risks of human exposure to a given
chemical. Therefore, the subchronic study should define target organs and tissues in a
manner sufficient to provide the basis for risk estimation. The studies should provide
(a) the demonstration, with appropriate methods, that the toxic effects observed at
the high-dose level are not observed  at least at the low-dose level and (b) the
delineation of tests that would also evaluate potential effects from long-term exposure
conditions. The results from the subchronic study should be applicable to potential
exposures of longer duration; however, it is not expected to be all-encompassing and
predictive of such effects as carcinogenicity, teratogenicity, certain reproductive
effects, or effects on longevity.

    The  workshop objectives included
• critically examining the subchronic study as it might be applied to general chemical
  testing programs and evaluating the effect of variations  in study parameters on
  assessment potential;
• identifying the deficiencies in the existing scientific knowledge and recommending
  research to strengthen the testing program; and
• identifying the related  scientific  issues to be resolved in future workshops or
  experimental programs.

            2. RELATIONSHIP OF PROTOCOL DESIGN TO
                     CHEMICAL CHARACTERISTICS

    The experimental design is based on the utilization of information available from
physical  and chemical data, acute studies, and structure-activity analogies with
known substances. Variations in subchronic toxicological evaluations may be
indicated for  different chemical classes and characteristics. However, current
knowledge does not permit development  of a specific and definitive test design for
each  identifiable chemical class.

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                                          17

     The outline design is based on the fundamental premise that a subchronic study
is rarely conducted in the absence of prior information on the test chemical. The
physical and  chemical data listed  in Table  2 will  usually be  known  for the  test
substance. In addition, the investigator will usually  have an indication of the acute
toxicological response. It is this information (Table  3) considered together with the
physical and  chemical properties  and, when available,  the biological activity  of
analogous structures  that will determine the  design of the subchronic study. Other
experimentally derived  data regarding biological  disposition  of the  toxicant, if
available, should be utilized.

                       Table 2. Chemical and physical information
                                Molecular weight
                                Molecular formula
                                Structural formula
                                Electrophile/neutrophile
                                Purity
                                Acidity/alkalinity
                                Particle characteristics °
                                Density
                                Corrosivity
                                Solubility in H2O
                                Lipid solubility
                                Melting point0
                                Boiling point"
                                Vapor pressure"
                                Dissociation constant (pK)
                                Stability  at various pH's
                                Stability  to heat and light
                         Relative to route of administration.


                           Table 3. Acute toxicity information

                 Time to onset of signs as a function of dose
                 Time to recovery
                 Weight changes
                 Organ effects
                 Observation of skin, fur, eyes,  mucous membranes, etc.
                 Changes in behavior
                 Signs of autonomic nervous system effect, such as tearing,
                     salivation
                 Changes in respiratory rate; depth and signs of respiratory
                     irritation
                 Cardiovascular changes, such as flushing
                 Central  nervous system changes, such as tremors, convulsion,
                     coma
                 Observation of dropping pans for evidence of eating or
                     noneating, urine color and volume, diarrhea
                 Time of death
                 Necropsy findings
                 Slope of the dose response line

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                                      18
    The information depicted in Fig. 1 allows the investigators to make one of the
following choices: (1) adequate data are available to predict hazard and a subchronic
test is not necessary; (2)  adequate data are not available to predict hazard and a
routine subchronic test is needed; (3) the data indicate that because certain effects are
expected,  a modified  subchronic  study utilizing an  expanded protocol  with
nonroutine tests should be designed; and (4) the data indicate the need for a chronic
test that must be designed through use of a modified subchronic test. In some cases
additional information may be available to indicate that no more work is necessary.
This information may include available experimental data and such factors as the use,
distribution, and production volume of the compound, as well as the  likelihood of
human or environmental exposure.
    Structure-activity  correlations can  sometimes provide a priori  information
concerning biological activity  related to the molecular structure of the substance
under consideration. This information  can be used to make either quantitative or
                                                         ORNL-DWG  80-18344
                              Intended production
                               volume, exposure
                               potential, use, etc.
Acule toxicity
(see Table 3)
Data
input
                                                                        Decision
                                                                        level 1
                                                                        Decision
                                                                        level 2
                Fig. 1. Selection process for designing toxicity studies.

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                                      19

qualitative estimates of biological activity. The examination of structurally related
chemicals  of known  toxicity  which have physical-chemical properties (such  as
partition coefficients or Taft-Hammett constants for steric and electronic properties
of substituents) similar to those of the test chemical may be useful in estimating the
biological activity of that test chemical. This procedure may be of use either with a
homologous series of chemicals or with chemicals that act on similar molecular
targets. However, the necessary information for estimating biological activity may not
always be available for many chemicals.
    Some of the qualitative structure-activity correlations for the industrial chemicals
of interest may relate to the carcinogenic potential rather than the general toxic or
metabolic activity of the molecule. However, in the absence of experimental data,
qualitative structure-activity correlations have some use in the prediction of potential
target-organ toxicity or metabolic activity. Structure-activity correlations, therefore,
may be of assistance in selecting toxicological parameters for evaluation.
     In conclusion, much reliance in designing a subchronic study can and should be
placed on the physical-chemical profile of  the test compound and its intended use.
Biological data from acute studies can also provide some guidance. Data on uptake,
distribution, and elimination of a compound are dependent upon the availability of
appropriate analytical methodology. Structure-activity relationships should be viewed
and applied with caution and should never totally substitute for actual experimental
data.


                       3. EXPERIMENTAL DESIGN

                        3.1 Exposure and  Duration

    Routes of entry for the chemicals of concern are inhalation, ingestion, and skin
exposure. Ideally, the subchronic study should be conducted by the  route of major
concern relative to human exposure. It  is recognized, however, that the subchronic
study itself would generally  be conducted by one route of administration and that
multiple factors may be involved in the selection of that route.
    An important concept in subchronic toxicity testing is that repeated doses of a
substance, when adequate doses are administered, are likely to exert most of their
potential long-term effects within 90 d. A lifetime "no-effect" dose can usually  be
predicted from such studies, excepting  those effects referred to in the introduction.
Weil and McCollister (1963) assessed the predictability of lifetime no-effect doses from
subchronic data. Of 22 chemicals none  had a long-term no-effect dose that was less
than 1/20 of its 90-d no-effect dose. For most chemicals the ratio of the 90-d no-effect
dose and the long-term no-effect dose was  less than 10:1. The review of McNamara
(1976) also supports these conclusions. Durations of less than 90-d have also been
evaluated.  Weil et al. (1969) found that even 7-d test results might  be a sufficient
indicator of long-term toxicity if used with a safety factor of appropriate magnitude.
However, few references in the literature assess clinical and pathological effects for
the shorter term with the 90-d studies.
    In the majority of cases, per oral and inhalation studies should be accomplished in
3 months. In most inhalation studies comparable results will be obtained from either

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                                     20

the 5- or 7-d/week exposures. The inhalation exposure schedule should be5 d/week,
6 h/d. For repeated dermal route studies, a maximum of 21 applications to rabbits on a
5-d/week basis is considered to be practical and of  sufficient duration because of
irritation and  stress  from repeated  applications,  daily  restraint,  and possible
intercurrent infections.

                                 3.2 Dose

    To establish the extent of the toxic response, the highest dose should provide a
distinct toxic effect but not lethality, whereas the lowest dose should produce no
detectable  toxic effect.  To obtain maximum information  on the dose response
characteristics of the chemical, at least one intermediate dose is generally used.

3.2.1  Selection of doses

    Guidance  on the selection of doses for subchronic toxicity studies may be
obtained from  the results of prior acute and repeated high-dose studies. Assuming
that the LD50 of the chemical has been established, some fraction of that dose may be
assumed to be nonlethal but still toxic over the test  period. This dose usually falls
between 10 and 25% of the LD50, depending largely on the slope of the acute dose
response curve.
    For chemicals having a tendency for bioaccumulation, the selection of dose levels
is particularly difficult. Pharmacokinetic studies may assist in selecting the dose levels,
because  the elimination pattern may  provide guidance on the extent of possible
bioaccumulation. However, many of these factors may be unknown when the study is
designed, so alternative approaches have been utilized for this purpose. Preliminary
range-finding tests using 5 or more groups of rodents (perhaps as few as 2 or 3 animals
per group)  for a period of 3-4 weeks, with doses at twofold to fourfold intervals can be
used  to select dose levels.
    The high-dose level should produce some significant toxicological effect without
a  high incidence of  mortality that would  prevent meaningful  evaluation.  The
successful  selection of a high  dose that will produce these adverse  but nonlethal
effects is partially related to the results obtained from these studies.

3.2.2 Limitations of maximum levels

    Occasionally, toxicological effects are not observed with a chemical even when
very  high doses are administered in a subchronic study. In such cases,  there are
maximum  dose levels that need rarely be exceeded. In these studies, the maximum
dose  levels should not  cause  nutritional imbalance  and/or  affect  the defense
mechanisms. Maximum dose levels are considered to be 5% of the  diet or 2.5 g/kg of
body weight per day  for peroral administration, 2 g/kg  of body weight per day for
dermal exposures, and 20 mg/m3 (6 h/d) for inhalation of  particulates, gases, and
vapors.
    Whenever these maximum dose levels are  to  be  exceeded in  actual use by
humans, levels higher than these maxima should be used in subchronic studies, and
care  should be taken to avoid complications from artifacts that would prevent

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                                     21

 meaningful utilization of the data. In some cases, factors such as low-vapor pressure,
 explosive limits, inability to achieve chamber concentrations, and insolubility and
 instability in vehicles may further limit the practical attainment of the desired high-
 dose levels. In a few cases, a chemical with low acute toxicity intended for low-volume
 productions may not be available in sufficient quantity to provide the desired high-
 dose levels in a subchronic study.
     Because in this case the desirable objective of the subchronic toxicity test is to
 establish dose response patterns and no-observed adverse-effect levels, a minimum of
 three dose levels including at least one intermediate dose is generally used.

                           3.3 Species Selection

     The animal species whose biological  processing of the material being tested is
 most similar to man's should be used for subchronic experimentation. Because such
 information may be unavailable when subchronic studies are initiated, it is suggested
 that at least the rat, and probably the dog, be employed. Because in some instances
 the rat's sensitivity has been equal to or greater than the dog's, the rat has been at least
 as useful as the dog in detecting the lowest level at which an effect has been observed
 (Avidao  1978). However, the dog has shown greater sensitivity in other instances
 (Litchfield 1961; Homan  1972). In special circumstances, with a small number of
 chemicals, other species have been shown to be more sensitive than either the rat or
 the  dog  (Smith 1979). However,  the use of additional species would often not
 appreciably affect the determination of a safe exposure level  for man.

                          3.4 Number of Animals

     The number of animals to employ in subchronic tests varies depending on the
 goals and needs of the  investigator. The participants disagreed concerning the
 appropriate level of statistical analysis and  the value of clinical chemistry/hematology
 tests. Therefore, two sets of animal numbers were suggested. If biochemistry and
 hematology tests are to be used as a major part of the assessment of toxic effects, then
 20 rats per sex per  level and 5 dogs per sex per level are necessary. If less use is made
 of clinical chemistry tests, then the numbers suggested are 10 rats per sex per level
 and 3 dogs per sex per level. For repeated skin application studies, 5 rabbits per sex
 per dosage level are recommended. Increasing the number of animals per level above
 that recommended  will  markedly increase the cost and decrease the efficient
 utilization of facilities and personnel; therefore, the choice of 3 dogs and/or 10 rats, or
 5 dogs and/or 20 rats, should be justified by the investigator.

                            3.5 Age of Animals

     In selecting the age of animals for use in a subchronic toxicity study, the ideal
 situation would have all age groups represented. Use of the neonate or fetus would
 allow the evaluation of toxic effects of chemicals on the earliest life stages. It would
 also be valuable to assess the toxic effects in older animals near the maximum life
span. This would provide an estimation of the potential toxic effects for all ages of the
human population.  However, this ideal situation cannot easily be achieved because of
such practical considerations as  the needs to establish baseline data,  allow for

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acclimatization to the housing conditions,  ensure  the  absence of nontreatment
diseases, and even acquire test animals. All these require time and prevent the use of
extremely young animals. Interference from normal aging effects and the difficulty in
obtaining sufficient numbers of older animals of the same age make the use of older
animals very difficult also. The subchronic test cannot be used to evaluate specific
age-related effects either in the fetus, neonate, or older animals. Special studies would
be required for such data. Therefore, in routine testing it  is generally recommended
that rodents  be started on  treatment  as young  as  practically  possible. This
conceivably could be from 3 to 4 weeks of age; however, a  period of 2 to 4  weeks
usually is needed to  assess the health and maturity  of the animals and to perform
pretest procedures. Thus, the earliest practical age to start rodents on test is 5 to 8
weeks.
    For nonrodents, especially the dog, it is important that the animals have reached
stabilized  baseline levels for the  biochemical/clinical parameters before they  are
started on  test. Stabilization for many parameters, especially enzymes, often does
not occur before 4 months of age in dogs because of variability in age of maturation
and other  reasons. For  practical reasons and in keeping with the desirability of
utilizing young adults, starting dogs on test at 4 to 10 months is  preferable to using
older animals.
    Generally, young albino rabbits are used for dermal toxicity tests. It is suggested
that rabbits weigh between 2 and 3 kg at the start of the study. Selection of other
species or other age or weight ranges for dermal toxicity tests may be acceptable but
should be justified.


                 4. EVALUATION OF TOXIC EFFECTS

                             4.1 Introduction

    A series of interrelated tests are suggested for the general evaluation of biological
systems, within practical constraints. In accordance with  good laboratory practices,
physical and clinical laboratory procedures will be used as indicators of toxicity, and
tissue histopathology examinations will be performed on selected target organs.
Additional clinical, laboratory, and pathological tests may be employed if the indicator
evaluations suggest abnormalities. The underlying purpose  is to use cost-effective
techniques to identify probable biological injury, which may then be examined in more
detail. The following  section discusses these tests and suggests a test design that
provides a comprehensive evaluation.
    The section is not meant to imply that only studies utilizing all these specific tests
or combinations of these tests will be accepted by the  EPA for TSCA regulation. The
following discussions are included as examples of properly  designed studies in which a
complete array of toxicity evaluations are interwoven to achieve a satisfactory level of
hazard assessment in a cost-effective manner. By indicating the perceived advantages
of each test, the Clinical Evaluations and  Pathology Committee hopes to provide a
scientific basis for the selection of tests to include in a subchronic study design and yet
avoid becoming rigid and overly complicated.

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                                     23

                4.2 Clincial Observations and Evaluations

    General clinical observations of experimental animals can include the periodic
(preferably daily) evaluation of general health, physical activity, and behavior, in
addition  to observations  on the  function of  specific  systems,  such as  the
cardiovascular, reproductive, eye and special senses, and central nervous system. In
some instances, because of the animal species involved and the physical restraints of
size  and anatomy,  certain suggested examinations  and procedures will not be
physically possible or practical (e.g., some procedures that are used in the dog may
not be practical in the rat).

4.2.1 Physical

     Experimental animals  should be  observed daily by trained and experienced
laboratory and/or veterinary personnel (Balazs  1970; Benitz 1970; Janku and Krsiak
1973; National Academy of Sciences 1975; Prieur et al. 1973; Spurling 1977; Zbinden
1963). Physical observations include those of respiratory activity; appearance of the
eye (e.g., cloudiness of cornea, conjunctivitis, discharge); nasal discharge; mucous
membranes; skin color; and hair or coat appearance.
     When practical, the heart and respiratory rates may be estimated by observation
or by palpation upon routine handling (Benitz 1970). Quantitation of these rates may
be performed when physical observations suggest a possibility of abnormality. Body
temperatures  may  be taken  if  the need  is  indicated  by the results  of  other
observations, but in general, daily temperatures or exact pulse and respiration rates
are too variable to be very useful in toxicological testing.

4.2.2 Health

     Evaluation of the following parameters should be performed daily on a qualitative
basis (Barnes and Denz 1954; Benitz  1970; Stevens 1977): appetite, presence and
character of feces, water  consumption  when practical, presence  of urine, and
abnormal urinary consistency or color.  When abnormalities  are  noted, urinary
volume may be measured. Each animal should be weighed and its food consumption
estimated at least once a week (Arnold etal. 1977; Barnes and Denz 1954; Benitz 1970;
Smith 1950). A weekly determination of weight  is suggested because body weight is
often the only or earliest indication of toxic effects, and it ensures that every animal will
have a weekly physical examination.

4.2.3 Cardiovascular

    A specific daily or weekly evaluation of the cardiovascular system is generally not
necessary,  unless physical observations suggest abnormalities or unless chemicals
suspected  of  affecting  the cardiovascular  system  are  involved.  Then special
examinations (e.g., electrocardiogram or blood  pressure) may be performed (Benitz
1970).
    Occasionally special monitoring of heart function will be an important part of
toxicological studies, because at a specific concentration some chemicals will affect
myocardial membranes enough to produce electrocardiographic changes. Among

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                                     24

laboratory animals the techniques of collecting and evaluating an electrocardiogram
(EKG) is adequately developed only in the dog (Detweiler, Huben, and Patterson
1960; Detweiler and Patterson 1965). In addition to before dosing and at the end of the
study, EKGs should be taken during the first week of the study because significant but
transitory cardiotoxic effects may occur early in the dosing regimen. The frequency of
further testing is determined by the necessity to detect any suspected change early
and  by  the desirability of following the development of such cardiac alterations
including any  possible  recovery. The time of day the EKG  is taken should be
determined in relationship to the metabolism and kinetics of the compound; generally,
it should be taken at the time of the chemical's peak cardiac effect.

4.2.4 Reproductive

    The most reliable early detector  of an abnormality of the male reproductive
system is histologic examination of the testes and epididymides, after proper tissue
collection and  fixation. When the prior history of the chemical suggests a potential
effect on reproductive function, the male reproductive system may be monitored by a
semen evaluation obtained by electroejaculation or another method. Semen samples
may be evaluated for quantity and  sperm motility, count, and morphology. This
evaluation is not a routine procedure.
    During clinical examinations of male dogs, palpation of the testicles for abnormal
swelling and softness as well as the prominance and delineation of the epididymides
may be  useful in detecting toxic insult to these organs. Subchronic studies do not
include an adequate  detector of reproductive ability in the female; such detection
would require a separate specific study.

4.2.5 Ocular
    On a routine basis the sight of the animal may be evaluated by observing its usual
movements within its housing area. Visual examination of the external eye is usually
performed as part of the routine physical examination (Balazs 1970). If visual defects
are  suspected,  further  perception studies  or  more  detailed  ophthalmologic
examinations should be performed. Biomicroscopic (slit lamp) examinations may be
used for large  animals (i.e., dogs and monkeys).
    Ophthalmologic examinations are an essential part of subchronic toxicity studies
(Benitz  1970;  Grant 1974;  Meier-Ruge  1977). They  should be conducted on a
representative number of the animals in the control and high-dose groups before the
study and at its termination, because ocular lesions generally develop slowly and are
seldom reversible (Grant 1974; Meier-Ruge 1977). If periodic or progressive changes
are expected and if it is necessary to document the development of such changes,
more frequent examinations may be  performed.  These examinations should be
performed by a qualified person.

4.2.6 Behavioral
    Evaluation of behavior has traditionally been incorporated  into toxicology
procedures (Balazs  1970; Benitz 1970; Janku and  Krsiak  1973; Prieur et al. 1973;
Zbinden 1963). Many of the observations can be done routinely during the physical

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                                     25

examination, which can include such tests as evaluation of the animal's attitudes (is it
alert or lethargic?), postural activities (movement and carriage of portions of the body,
limbs, and head), responsiveness to demand (ability to move when prodded), and
general behavior (is it suddenly aggressive or depressed from previous observation?).
Such observations may be easily performed by trained persons familiar with the
animal's usual behavior.
    Evaluation of hearing may be determined by the animal's carriage and movement
of ears or by the introduction of unexpected external noise into the environment.
Such evaluations are relatively arbitrary and have not been standardized.

4.2.7 Neurological
    Specific neurological examination may be performed monthly or when indicated.
In rodents, this evaluation may consist of balance beam or rotating-rod procedures; in
dogs  more detailed studies may be performed,  such as electroencephalograms
(EEGs) (DeLahunta 1977; Hoerlein 1971).
    A detailed clinical and, when possible, instrumental neurological examination
should be made if it becomes apparent that treatment-related signs of nervous system
abnormalities are present. The objective of the test should be to determine the
location  of  the  lesions so  that  ultimately these areas can be  evaluated  by
histopathologic or ultrastructural examination.
    When neurological examinations suggest some abnormality, it is likely that
continued  exposure  to the  chemical  compound in question  could produce
morphologic changes in the peripheral nerves or central nervous system. It may be
appropriate in such cases to proceed with special additional studies at higher doses
and more  concentrated exposures  to  provide definitive  morphologic-pathologic
changes for better interpretation of these toxicologic effects.

4.2.8 Memory and learning

    Memory and learning studies are recent additions to special toxicologic studies
and are generally not included in routine subchronic studies. Memory and learning
patterns of rodents and dogs may  be  tested and evaluated during and following
exposure to chemicals. The procedures are currently limited to simplistic studies of
primitive learning patterns or abilities to remember trained or conditioned activities.
Mazes or pedal-pressing and  reward trials  may  provide preliminary evidence of
alterations in nervous system function.

                       4.3 Clinical Laboratory Tests

    The laboratory procedures used for monitoring animals in  subchronic toxicity
experiments  are usually tests  that have  been developed for diagnostic purposes.
Tests developed for one species are usually appropriate for another but need to be
modified because of quantitative differences. In monitoring animals in toxicological
studies to detect early deviations from normal, absolute precision, accuracy, and
sensitivity of test procedures are required.
    The test selected should be appropriate for the animal species being utilized, be
selected to monitor a particular major organ or to react to a broad range of biological

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                                    26

changes, and be the most sensitive in the normal range for that species. The test
procedure should be sufficiently precise so as not to add to the total statistical
variation of the results and allow comparison of results between laboratories.

4.3.1  Sampling  frequency

    The following suggestions are based on the use of the rat and the beagle dog as
the test animals.
    Because of the undesirable effects caused by frequent blood sampling, care
should be taken not to collect at one time more than 10% of the animal's total blood
volume. More than this will stress the capacity of the animal to regenerate lost red cells
and would deplete the stored iron so that the data generated under these conditions
would be compromised.
    If possible all animals inthe control and experimental groups should be sampled
at least once before the dosing is initiated. Half of the rats in each group should then be
sampled at one week, one month (and if the study warrants,  every six to eight weeks
thereafter), and at the termination of the study. Precautions should be instituted so
that excessive sample removal does not affect body weight gain (Cardy and Warner
1979). The remaining half of each rat  group should be sampled only at the study's
termination. Because of larger blood volumes, all the dogs in each group should be
sampled at each sampling period and termination.  Because of the expenditure of
resources and the energies devoted in these types of studies, prior consultation with
biostatisticians is recommended.

4.3.2 Hematologic evaluations
    General hemalologic examination consists  of cellular evaluation and hemostatic
function evaluation. This might include packed red cell (PCV), which is the most
reliable method of all the erythroid measurements on peripheral blood (Linman 1966);
hemoglobin concentration (Hb), which is an excellent screening test (Wintrobe et al.
1974), especially the cyanmethemoglobin method recommended by the International
Committee for Standardization in Hematology (Lewis 1967); erythrocyte enumera-
tion (RBC),  which is necessary for assessment of erythrocyte numbers and may be
required for the calculation of mean corpuscular volume (MCV); mean corpuscular
hemoglobin concentration (MCHC), which can be derived either from  manual or
automated methods, which is remarkably constant throughout vertebrates, rarely
exceeding 37 g/dl (Medway and Geraci 1964; Hawkey 1977), and which can also serve
as a quality control measure verifying the compatibility ofHb and PCV; MCV, which is
directly measured in some electronic particle counters or may be obtained from RBC
and PCV values; total and differential white blood cell  counts (WBC), including
absolute values, which are basic parameters for leukocyte evaluation; blood smear
examination including morphologic  evaluation of  erythrocytes,  leukocytes, and
platelets and of their relationship to the quantitative data (Archer 1977; Wintrobe et al.
1974; Carrwright 1968; Linman 1966); prothrombin time (PT) (in dog only), which is a
nonspecific screening test measuring an overall functional ability of the extrinsic
coagulation system; and activated partial thromboplastin time (APTT) (in dog only),
which is a nonspecific screening test  measuring an overall functional ability of the

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                                      27

intrinsic coagulation system. Mean corpuscular hemoglobin is not suggested because
its usefulness may not be commensurate with the expenses involved in generating and
storing data.
     Special tests, in addition to the standard screening tests, may be done when
quantitative parameters are different statistically from those of control values by ±2
standard deviations (or by other justifiable standards), or when qualitative assays or
clinical signs suggest a treatment-related hematologic abnormality. Special tests may
include but are not limited to reticulocyte count, platelet count (smear confirmation is
always necessary),Heinz bodies detection, methemoglobin determination, glucose-6-
phosphate dehydrogenase  (G-6-P-D)  estimation, pyruvate kinase (PK), platelet
aggregation, erythrocyte fragility, and iron determination and stain.
     At termination a routine hematologic study is to be performed. If a treatment-
related hematotoxicity is present, a more complete hematologic evaluation including
PT, APTT,  and bone marrow smear  should  be   performed, together  with
histopathologic examinations of the hematopoietic organs.

4.3.3 Clinical chemistry evaluation

     The following is a list of commonly used clinical chemistry determinations which,
used as a  unit, can provide a fairly complete chemical  analysis screen of toxicity
(Kaneko and Cornelius 1970). However, it is not implied that these tests can totally
substitute for the use of histopathology or that these tests are the only clinical studies
that will be acceptable by  the EPA. The intent of this  discussion is to suggest a
practical clinical chemistry screen that may be used with histopathology to evaluate
the majority of the body systems.

• Glucose (fasting blood): Is the best single parameter of carbonhydrate metabolic
  status and pancreatic islet cell intergrity. It also reflects nutritional state and
  physiological stress.  For  example, it  can reflect adrenal, thyroid, and, indirectly,
  pituitary function.
• Glutamic-oxaloacetic transaminase (GOT): Reflects injury to the skeletal muscle,
  cardiac muscle, and liver. Because it is found in high concentration in the RBC, it is
  also useful as an indicator of the quality of the blood sample.
• Glutamic-pyruvate transaminase  (GPT): Reflects  liver injury in carnivores and
  omnivores.
• Cholesterol:  Reflects nutritional status, pancreatic islet cell damage (diabetes),
  thyroid function, and cholestatic liver  injury. In this unit of 13 recommended tests, it
  is the best for reflecting thyroid function.
• Total protein: Reflects nutritional status, liver injury, intestinal injury, renal injury,
  and  several other pathological states.
• Albumin: Reflects protein  imbalances  and  is  required  for proper screening
  interpretation of the total protein.
• Globulin: Reflects the presence of some  lymphoreticular tumors,  acute inflamma-
  tion,  liver injury, chronic suppurative disease, renal disease, and several others.
  Globulin is obtained by difference between total protein and albumin. If the protein,
  albumin, or globulin falls outside two standard deviations from the mean or if other

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                                     28

  statistical parameters indicate chemical related variations, the proteins should be
  electrophoresed to obtain accurate values for levels outside the normal range.
• Sodium:  Permits  evaluation of  acid/base  imbalances,  adrenal  function, and
  intestinal injury.
• Potassium: Permits  evaluation  of acid/base imbalances, adrenal function, and
  intestinal injury, but  always used in conjunction with sodium.
• Alkaline phosphatase: May reflect bone injury, hepatocellular disease, and adrenal
  hyperfunction (dog).
• Calcium: Permits assessment of the status of bone and of nutrition.
• Phosphorus:  Reflects bone injury, renal disease, and nutritional status.
• Blood urea nitrogen (BUN): Reflects renal injury, prerenal and postrenal azotemia
  and advanced liver disease.

     All of the above tests can be performed with approximately 0.75 ml of serum,
which in  the normal animal may be obtained from 2.0  to 2.5 ml of whole  blood.
Because of the volume, the use of rats with body weight of less than 200 g is a limiting
factor. Therefore, it may not be possible to do all the suggested tests at all the sampling
intervals.  However, all tests can be done on the blood collected at the termination of
the  study. The  combination of tests to be  performed should be justified by the
investigator.

                       4.4 Special Organ Evaluation

     When data indicate that a particular organ or organs are  affected, certain
additional  tests may be suggested to specifically assess damage to that target organ.
The  merits of these tests should be properly evaluated.  Tests would normally be
similar for all species tested, such as the rat and the dog, if practical aspects make their
use feasible. Pulmonary function tests are not specifically  listed, because, except for
inhalation  toxicity studies, lung changes would not ordinarily occur; but where such
damage might  be present,  pathological examination of lung tissue is the  most
appropriate means of determining its extent and significance.  When extrapolating
data to man, it is especially important to recognize the unique differences expected
between various experimental animal species in their responses  to chemicals as
reflected in their organ function tests. It is necessary to have trained and experienced
comparative pathologists and toxicologists available for such  interpretation. The
following discussion contains some suggestions for such  assessments.

• Adrenal. In addition to sodium, potassium,  and alkaline  phosphatase, special tests
  to provide a definitive clinical laboratory evaluation of the adrenal gland are cortisol
  and the adrenocorticotrophic hormone (ACTH) response test.
• Bone.  In addition to calcium, phosphorus,  and alkaline phosphatase, a special test
  is  parathormone. Other histopathologic approaches may be more cost-effective.
• Brain and nervous tissue.  If clinical signs and results of other tests warrant,
  creatine phosphokinase (CPK) and isoenzymes may be determined, in addition to a
  study of cerebrospinal fluid (chemistry and cytology).
• Intestine. In addition to  total protein, albumin,  globulin, sodium, and potassium,
  special tests may include serum protein electrophoresis; amylase (dog); absorption

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                                     29

  tests for fat, glucose, and xylose; serum chloride; total plasma carbon dioxide; and
  qualitative or quantitative tests for fecal fat, protein, and carbohydrate.
• Kidney. In addition to BUN, total proteins, albumin, and globulin, special tests may
  include creatinine; endogenous urea clearance; endogenous creatinine clearance;
  urinalysis; and serum protein electrophoresis.
• Liver.  In  addition to  GOT, GPT,  albumin, globulin,  total  protein,  alkaline
  phosphatase  (AP),  and cholesterol, special tests  may  include serum protein
  electrophoresis, direct and indirect bilirubin, gamma gultamyl transferase (GGT),
  lactate dehydrogenase (LDH) and its isoenzymes, Bromsulphalein (BSP) retention,
  serum bile acids, and biopsy.
• Muscle. In addition to GOT, special tests may include CPK and isoenzyme, LDH
  and its isoenzymes, and biopsy.
• Heart. In addition to GOT, special tests may include CPK and and its isoenzymes
  and LDH and its isoenzymes.
• Exocrine pancreas. In addition to total protein, albumin, globulin, sodium, and
  potassium, special tests  may include  amylase  and  lipase; serum protein
  electrophoresis; fecal trypsin; absorption tests for fat, glucose, and xylose; and
  qualitative or quantitative tests for fecal fat, protein, or carbohydrate.
• Endocrine pancreas. In addition to glucose, sodium, and potassium, special tests
  may include intravenous glucose tolerance tests, insulin response to glucose loads,
  and urinalysis.
• Thyroid.  Special tests  may include triiodothyronine by radioimmunoassay  (T3),
  thyroxine  by  radioimmunoassay (Tn), and the thyrotropin response test.

                         4.5 Urinalysis Evaluation

    Although most toxicology guidelines recommend urinalysis as a test parameter
(Federal Register  1978; Food Safety Council  1978;  Prieur et al.  1973;  U.S.
Environmental  Protection Agency 1979), it  was the consensus  that routine and
detailed evaluation  of randomly selected urine samples normally has  a  minimal
usefulness in subchronic  studies. If any urinalysis is performed, it is suggested that
nonrodents be  used and rodents only when  there is a need based on expected or
observed toxicity. Among the parameters that could be assessed are color, specific
gravity or osmolarity, pH, protein, glucose, ketones,formed elements (RBCs, WBCs,
epithelial cells, etc.), crystalline and  amorphous materials, and blood  pigments.

                               4.6 Pathology

4.6.1  Gross examination

    Qualified scientists  should perform or  personally  supervise the necropsies,
and/or be immediately available for consultation at the site. Other trained employees
may assist in the necropsies.
    Animals must be necropsied as soon as possible after death. If necropsy cannot
be performed immediately after the animal is killed,  or  found dead, a trained
technician should immediately refrigerate (but not freeze) the animal at temperatures
low enough to minimize  tissue  autolysis (4-8°C). Animals found dead upon routine

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                                     30

clinical examination should  be  necropsied as  soon as possible to salvage usable
tissues. Animals found moribund should be sacrificed to assure the collection of
usable tissues.
    The gross examination should include an initial physical examination of  the
external surfaces and all orifices, followed by an examination of tissues and internal
organs in situ. The examination should include the following: external and internal
surfaces of all hollow organs; cranial cavity and external surfaces of the brain and
spinal cord; nasal cavity and paranasal sinuses; neck with its associated organs and
tissues; thoracic, abdominal, and pelvic cavities with their  associated organs and
tissues; and the musculoskeletal system including testing manual-breaking strength of
a long bone or rib. (The  latter procedure may be employed by the experienced
pathologist with reliable results and is more practical than  elaborate instrumental
techniques.) In inhalation studies and where pulmonary damage is indicated, the lungs
should be  inflated with  a  fixative to  allow  for  better  gross examination  and
preservation. A minimum of 20% of the lungs from different groups should be so fixed,
with 50-75% fixed, in special instances, by the  intratracheal perfusion technique.
    The weights of the liver,  kidneys, uterus, prostate (dogs only), and seminal
vesicles (except for dogs) should be recorded. In experiments involving chemicals
with suspected hypertensive effects, the weight of the heart should be recorded. Also,
in experiments in which the chemicals have a  hormonal effect, the weights of  the
gonads and the adrenals should be recorded.

4.6.2  Tissue preservation

    The prosector should immediately preserve all tissues and organs from all test
animals in  10% buffered  formalin or another  recognized  and accepted fixative
appropriate for the specific tissue(s) (Luna 1968). Sections (blocks) from the following
tissues from all test animals, regardless  of their time of death, should be properly
preserved and routinely examined microscopically:

• all gross lesions, with a margin of normal tissues;
• brain, minimum of one transverse section each from the forebrain, midbrain, and
  hindbrain;
• spinal cord, minimum of one  section from the thoracic region;
• eye and attached optic nerve;
• a major salivary gland;
• thymus;
• thyroid;
• heart, two sections, one through a left papillary muscle and one through a coronary
  artery;
• aorta;
• one lung with a major bronchus;
• stomach, fundic and pyloric regions;
• small intestine, three levels;
• large intestine, one  level each of cecum and  colon;
• adrenal gland;
• pancreas;

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                                      31

   liver, one lobe (a minimum of one left and one right lobe when gross lesions or other
   evidence of hepatotoxicity are present);
   gallbladder, if present;
   spleen;
   kidney;
   urinary bladder;
   mesenteric lymph node, plus tracheobronchial lymph nodes in inhalation studies
   and regional lymph nodes in dermal toxicity studies;
   bone, including marrow;
   skin, only required in dermal toxicity studies and should be selected from skin
   painting sites and normal areas;
•  skeletal muscle, selected if there are clinical signs, gross lesions, or changes in
   appropriate  serum enzymes  (contraction artifacts should  be prevented and
   enzyme histochemistry used when fiber types need to be identified); and
•  reproductive organs, testes, and epididymides or uterus and ovaries.

     The testes and epididymides, sectioned into 0.5-cm slices, should be preserved in
Bouin's solution or other appropriate fixative to  ensure a high quality histologic
section. For detecting impairment of fertility in the male, this is the only method that is
routinely done in these end-point toxicity studies. Based on experience, or scientific
or practical judgments, other tissues may be preserved for later study.

4.6.3 Justification of selection of tissues for histopathological examinations

     Histopathological examination of tissues is expensive, and in some organs it is
not the most reliable or sensitive detector of damage (Smith, Jones, and Hunt 1972).
Therefore, we have attempted to monitor changes in organs by those tests that are
most sensitive and least expensive. Microscopic examination of some tissues included
in other guidelines have been omitted from routine examination here when there is no
gross lesion, no change in appropriate clinicopathologial parameters, or no evidence
of toxicity from previous studies. However, monitoring of these organs has been done
by other means (e.g., weighing organs, clinical pathology, or necropsy observations),
although histopathologic examination may still be required in some studies. Except
where observations indicate, the histopathological studies should be conducted on
control and high-dose groups only.
     For paired organs, it is necessary to examine only one if both are grossly normal
because exposure is via the bloodstream and thus change is assumed to be bilateral.
Only one lobe of the liver is sampled, if normal. If lesions are present, both a right and a
left lobe should be sampled. Since portal streaming occurs in some species, an orally
ingested  toxicant could affect one lobe more than another (Popper and Schaffner
1974). For instance, toxicants absorbed from the small intestine could affect the right
lobes more severely.
     Parathyroid function is usually monitored by checking the breaking strength of
bones  at  necropsy, the appropriate  clinical pathology  parameters (e.g., serum
calcium), and, in dogs, the size of the gland at necropsy. Because lesions in grossly
normal parathyroids are infrequently detected in Hematoxylin and Eosin-stained
(H&E) sections (Robbins 1967), histopathological examinations of the parathyroids
will not be done routinely.

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    The trachea need not be examined microscopically in oral or dermal studies,
because they are unlikely to be exposed to significant concentrations of the test
material. If material is regurgitated and aspirated into the  trachea and lungs, any
changes would be detected in the sections of bronchi and lungs. The trachea should
be examined at necropsy.
    The esophagus is not routinely examined microscopically, because it has only
transitory contact with ingested material. It is examined at necropsy and sectioned if
there is a gross lesion. Irritant chemicals would produce gross lesions and/or clinical
signs.
    The changes  in weight of the uterus and the prostate-seminal vesicle  are
monitored, because the weight changes are a more sensitive and earlier indicator than
microscopic examination. Early hyperplastic changes in prostates are especially
difficult to confirm by histopathological examination alone.
    No separate collection  of small arteries is required, as they will be examined in
numerous other tissues.
    Routine histologic examination of apparently normal skin is unlikely to reveal a
lesion. Any skin lesion should be sectioned. The mammary glands can be examined
clinically and sectioned if any alterations in size or texture are detected during the
experiment or at necropsy.
    Bone marrow function is monitored routinely by complete blood count (CBC).
Hematopoietic  function  is routinely monitored by CBC examinations and, when
necessary, bone marrow smears. At necropsy histologic examinations are made of
sections of bone marrow, spleen, lymph  node,  and thymus.
    Histopathological examination of the H&E-stained sections of pituitary is not
likely to reveal treatment-related changes in a subchronic  study. Where there is
clinical or other indication of pituitary dysfunction, serial sections and appropriate
special stains (e.g., modified trichrome stains) should be prepared  (Luna 1968).
    Routine examinations of the liver,  gallbladder, kidney, urinary bladder, and
salivary gland are included, because these organs excrete foreign chemicals that are
absorbed into the  body.
    Treatment-related lesions in the heart are infrequent in experimental animals, but
because of the frequency of lesions in the human heart and aorta, these are routinely
sectioned. However, examination of these organs may not contribute significantly,
and this routine sectioning should be reevaluated when adequate data are available.
    Visual function can be monitored through changes in animal behavior and by
ophthalmological examinations. However, one eye and its attached optic nerve will be
routinely cross- and longitudinally sectioned because of the  possibility that animals
may have suffered visual impairment that escaped clinical detection.

4.6.4 Special considerations

    Postmortem artifacts in muscle contraction may be prevented by clamping or by
allowing the muscle energy stores to be depleted before fixation (Adams, Denny-
Brown, and Pearson 1962; Price et al. 1965). If lesions are suspected, then skeletal
muscles, particularly the weight-bearing muscles of the pelvic and pectoral girdles
(Bradley 1978), should be examined at  necropsy. During trimming, each muscle
should  be  identified  and cut in longitudinal and transverse sections,  and enzyme

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                                     33

histochemistry  (Dubowitz  and Brooke  1973)  and electronmicroscopy may be
necessary to characterize muscle lesions in more detail (e.g., to determine fiber types
involved).
    In an inhalation study, multiple sections of the upper respiratory tract, external
nares, nasal turbinates, nasal cavity, paranasal sinuses, hypopharynxlarynx, and
tracheobronchial lymph nodes should be  sectioned.

4.6.5 Central nervous system

    Successful detection of lesions in the nervous system depends on examination of
the correct sites. Because examination of the nervous  system is  difficult and
frequently impossible, a thorough clinical examination may assist in characterizing the
alterations.
    Where lesions of the central nervous system and peripheral nervous system are
suspected, transverse sections of the brain and cord are examined. Cord segments at
the levels of C2, C8, T7, and L& or Ly should be sampled. A minimum of six brain and
four cord segments is  preferred for the initial examination of the central nervous
system. The nature and location of the lesions should be characterized.
    For microscopic examination, brain and spinal cord sections should be chosen
based on clinical signs. In special cases, brain and cord may be fixed in situ by systemic
perfusion with 4% paraformaldehyde followed by 5% glutaraldehyde. In dogs with
clinical  signs but nonlocalized lesions, the  following  transverse sections of brain
should be considered for selection: corpus striatum, optic chiasma and optic tracts,
mammillary  bodies and  hippocampus, rostral colliculus, caudal colliculus, cerebellum
and medulla at the level of the pons, cerebellum and medulla at the level of the facial
nerve nucleus, medulla at the level of the vestibular nuclei, and medulla at the obex.
    Characterization of lesions should not depend on H&E-stained sections alone.
Selected electronmicroscopy, as well as special stains such as Holmes for normal
axons, Guillery for degenerating axons, Luxol  fast blue for normal myelin, Glee's
modification of Marchi for degenerating myelin, osmium tetroxide staining of teased
peripheral nerves, and Holzer's stain for glial fibers may be used where appropriate.

              4.7 Analysis and Presentation of Test Results

    The report of the subchronic study should contain a summary and analysis of the
data and a  statement of the conclusions drawn from the analysis. The summary
should highlight any and all lexicologically significant data or observations and give
the investigator's opinion as to the mechanism of the action of the toxicant, the target
organ or organs, and the sequence of pathological changes.

              4.8 Usefulness and Correlation  of Test Results

    This section on the evaluation of  toxic effects describes the usefulness and
correlation of sets of general observations, clinical laboratory tests, and pathology
examinations to be routinely evaluated in a subchronic toxicity study. It is suggested
that additional tests and examinations may be performed when appropriate. Table 4
shows how these three sets complement each other and allow evaluation of organs or
organ system(s) with the most appropriate and economical methods now available.

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                                           34
     Observations  in  subchronic tests  that  might  trigger further testing  were
considered. However, the variety of biological changes produced by chemicals is so
great and variable that no specific recommendations could be made.
           Table 4. General observations, clinical laboratory tests, and pathology examinations
                          that may be used in subchronic toxicity studies
Organ or organ
system
Liver





Gastrointes-
tinal (GI)
system

Urinary system

Hematopoietic/
hemostatic
system





Nervous system

Eye

Respiratory
system
Endocrine
system

Reproductive
system


Skeletal
system
Cardiovascular
system

Skin

Muscle



General observations
Discoloration of mucous
membranes, edema, ascites




Diarrhea, vomit, stool.
appetite


Urine volume, consistency.
color
Discoloration of mucous
membranes, lethargy.
weakness





Posture, movements.
responses, behavior
Appearance, discharge,
ophthalmologic examination
Rate, coughing, nasal
discharge
Skin, hair coat, body
weight, urine and stool
characteristics
Appearance and palpation
of external reproductive
organs

Growth, deformation.
lameness
Rate and characteristic of
pulse, rhythm, edema,
ascites
Color, appearance, odor.
hair coat
Size, weakness, wasting,
decreased activity


Clinical laboratory
tests on blood
Glutamic oxaloacetic trans
aminase (GOT) glutamic
pyruvate transammase.
alkaline phosphatase (AP)
cholesterol, total pro
tem. albumm globulin
Total protein, albumin.
globulin sodium (Na)
potassium (K)

Blood urea nitrogen total
protein albumin, globulin
Packed red cell volume
hemoglobin, erythrocyte
count, total and diffe1'
ential leukocyte count
thrombocyte count, blood
srnear. prothrombin lime
activated partial thrombo
pldstin time




Total protein, albumin.
globulin
Glucose Na K AP (dog)
cholesterol





Calcium, phosphorous
AP
GOT


Total protein, albumin.
globulin
GOT. creatme
phosphokmase


Pathology examination0
L,verb





Stomach GI lr(ict qall
bladder (if prtspnt)
salivary gland
pancreas
Kidney and urinary
bladder6
Spleen t hymns mesen
tenc lymph nodes.
bone marrow smear and
section




Brain, spinal c. ord and
sciatic nerve
Eye and optic nerves

One lung with a major
bronchus
Thyroid adrenal
pancreas

Testes and epididyinis or
ovaries Uterus or
prosiate and seminal
vesicles6
Bone and breakage
strength
Heart,*' aorta small
arteries in other
tissues
Only in dermal studies

Only if indicated by
observations, clinical
chemistry or gross
lesiois
    "All animals should undergo thorough gross examination, organs or tissues listed should be examined microscopically
    6 These organs should also be weighed

-------An error occurred while trying to OCR this image.

-------
                                     36

                 Table 5. Acute toxicity of nefopam in three species

                  Route           LD5°             L£>5°
                               (ma/kg)0      (95% confidence limits)

                                   Mouse
               Intravenous          45.5             36.5-54.3
               Intramuscular        52.9             413-67.7
               Oral              119               101-135
                                     Rat
Intravenous
Intramuscular
Oral

Intravenous
Intramuscular
Oral
28
569
178
Dog
-20
-30
> 100 < 200
25.0-31.4
47 4-68.3
146-217




                  Mg per kg of body weight
                 Source: Adapted from Case, Smith, and Nelson, 1975.

the route of administration (Table 6). He further suggests that comparative LD50's of a
compound given by different routes may allow prediction of information concerning
translocation,  deposition, inactivation, or site of excretion of the compound  in
question. He does not, however, suggest a rationale for estimation of toxicity of a
compound given by one route when information is available about the toxicity when
given by another route. Limited data from studies not  appearing in the available
literature suggest that route-to-route correlations and subsequent estimations are
possible for some compounds but not for others.
    Table 7 compares the results of two 90-d toxicity studies in rats with vinylidene
chloride (VDC). In both studies the  primary toxic sign, degenerative fatty  liver
changes, observed at daily doses of 28 mg/kg in the drinking water study and 42 mg/kg
in the inhalation study, was described as being slightly more severe by the inhalation
route. The correlation was also observed when similar experiments were performed
on fasted and nonfasted rats, even though toxicity was more severe in fasted than in
nonfasted rats. It appears that with this approach, which uses breathing rates of rats
and chamber  concentrations and  assumes 100% absorption,  there is a positive
correlation between the daily dose on a mg/kg basis and the observed toxicity for two
routes of exposure.
    Table 8 compares the toxicity of perchloroethylene (PERC) administered in rats
by either gavage or inhalation. In the gavage study PERC was administered in a  corn
oil solution daily at a dose of 500 or  1000 mg/kg for two years. In the inhalation study
rats were exposed to  10 or 600 ppm of PERC for one year followed by one year of
observation without exposure. Both studies reported that the only toxicity observed
was the early onset of mortality in males due to chronic renal disease. (Males of this
strain of rat have  a  naturally  high rate of spontaneous chronic  renal disease.)
Calculation indicates that doses of 10 and 600 ppm for 6 h/d approximate daily doses

-------
37

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-------
        Table 7. Comparative results of 90-d toxicity studies in rats administered
                  vinylidene chloride by drinking water or inhalation
                                Drinking water                Inhalation"
Concentration (ppm)
Daily dose (mg/kg)Q
Mean dose
Degenerative
fatty liver
50
5-12
Q
^ O
Absent

100
8-20
-14
Absent

200
16-40
-28
Present

25
14b

Absent

75
42 c

Present d

         Exposure for 6 h/d, 5 d/week.
         Mg per kg of body weight.
        cCalculated using breathing rate of rat and the concentration in air
        d Slightly more pronounced than that observed in the drinking water study
        Source: W. Braun, Dow Chemical Co (unpublished data)

          Table 8. Comparative toxicity in rats administered perchloroethylene
                             by gavage or inhalation

                                   Oral gavage                Inhalation
Concentration (ppm)
Daily dose (mg/kg)°
Early mortality males

500
Absent

1000
Present
10
20
Absent
600
1200
Present
        (chronic renal disease)
          °Mg per kg of body weight
          Source: Pegg et al., 1979

of 200 and 1200 mg/kg respectively. When this approach is used, there again appears
to be  a correlation between the observed toxicity studies and  the  daily doses
expressed on a mg/kg basis.
    These apparent correlations  of dose with observed toxicity for two different
routes of exposure should not be taken as a general correlation that will hold in all
cases.  The correlation noted for PERC is most probably reasonable and is easily
explained, because Pegg et al. (1979) have demonstrated that the pharmacokinetics
and metabolism of PERC are independent of the route of exposure. However, when
pharmacokinetics  and  metabolism  are  dependent upon  route  of exposure,
correlation with effect may not be apparent and extrapolation becomes more difficult.
    Table 9 summarizes the results from two chronic tox icity studies in rats with 1,4-
dioxane administered either via inhalation or drinking water. Previously mentioned
dose calculations indicate  no evidence of correlation between dose  and observed
toxicity. Young, Braun, and Gehring (1978) demonstrated that blood concentrations
of 1, 4-dioxane were comparable for estimated equivalent doses by either drinking
water or inhalation exposure. Liver concentrations of 1, 4-dioxane, however, were
much higher after oral administration.
    One of the factors that could form a potential basis for extrapolation, with some
degree of confidence, from one route to another would be an equivalence in peripheral

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                                      39
                Table 9. Summary of results from two chronic toxicity
                          studies in rats with 1,4-dioxane

                                   Drinking water           Inhalation
Concentration (ppm)
Daily dose (mg/kg)a
Toxicity

100
Liver
toxicity
111
1000 105
Tumors No toxicity
in liver or
othei organs
               ° Mg per kg of body weight
               Source: Adapted from Young, Braun, and Gehnng, 1978.

blood concentrations. However, this principle would not apply in situations like the
following.

• The organ of entry is the target organ. If an inhaled compound produces an effect on
  the lung, it would be unlikely (but not impossible, because there are systemic lung
  toxicants) that the effect would be produced by ingestion. Similarly, if ingested
  materials cause stomach damage it would be difficult to extrapolate that effect to a
  different route.
• The organ of entry to another organ or system is without the benefit of detoxication.
  Two examples are apparent. The effects of inhaled materials on the heart and the
  effect of ingested materials directly on the liver. In these examples the heart and
  liver are exposed to the material directly as it comes from the organ of entry. The
  concentration in the pulmonary and hepatic veins may be far greater than that in the
  peripheral blood, and thus the potential for effect is much greater for the heart and
  liver.
• The compound is highly reactive. In this case administration by various routes may
  result in totally different  target organs or metabolites.

     Generally, it is reasonable to assume that once a material enters the circulatory
system, its subsequent behavior is independent of route of administration. Thus, if the
blood concentration is known for two routes of administration as a function of time
and dose (exposure) and if the toxic effects  via one route are known, prediction of
toxicity by  the  other route  is possible.  In the  absence of either blood kinetic
information or exposure-blood level information, the  prediction of toxicity by  a
different route will be highly uncertain.
     In summary, few studies allow for estimations of the type mentioned above, and
many studies indicate that extrapolation from one route  to another  would be
impossible. In the absence of any other information and where some estimations are
needed,  the approach as outlined  by Stokinger  and Woodward (1958) could be
followed.
     This approach used  retrospective studies and standards for extrapolating data
from various routes of exposure to develop drinking water standards. Because much
work had been done on the classes of chemicals they were dealing with, the authors
relied heavily on established standards such as Threshold Limit Values for industrial

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                                     40

chemicals in air, federal tolerances for pesticide residues, toxicological classifications
by type of compound, and toxicity data from nutritional and other studies.
    The authors used similar adaptation techniques for data generated in animal tests
by various routes. The following summarizes the basics of the extrapolation process.

• For data from inhalation studies, LD50 or related values should be converted to a
  common dosage unit (i.e., mg/kg or mg/kg per day) through the use of standard
  respiratory parameters for the subject species over the exposure period. This
  adaptation must include the development of absorption factors that estimate the
  amount of  test material absorbed into the blood stream.  Use of these factors
  introduces greater uncertainty into establishing uniform exposure situations, but
  data from kinetic studies and physical characterization of the test material may
  diminish the uncertainty somewhat.
• For ingestion data, toxic values should be expressed in standard units suitable for
  conversion,  such as those listed above. An absorption factor must again be
  developed by using whatever data is available to diminish the inherent uncertainty.
• For dermal data, suitable dosage units can be calculated (but exposure times must
  be carefully studied in light of the  test design being reviewed).
• For parenteral data, similar standards can  be developed, but absorption factors,
  depending on the materials being studied, may be made with greater confidence.

    After conversion of known data to uniform dosage units, it follows that the
reverse process is  used to calculate  exposure concentrations, applied  doses, etc.
    Thus, the only available reference that suggests a reasonable approach  to the
problem of extrapolation from one route to  another appears to be Stokinger and
Woodward. In essence, it suggests a considered judgment of all available toxicological
data in attempts to carry out such an extrapolation.

       5.3 Factors Affecting Extrapolation of Data Obtained by One
                      Route of Exposure to Another

    The effect of route of administration on absorption, distribution,  metabolism,
excretion, and potential toxic response is well known. However, the committee felt
that a brief review of the  subject was worth including.
    "As a general rule... absorption of chemicals will be most rapid when given by
inhalation, less rapid when given by gavage, and slowest with dermal application"
(World Health Organization 1978, p. 68). The order is affected by the role of physico-
chemical factors in absorption. In general the skin is not highly permeable to most
chemicals and acts as a reasonable barrier against environmental chemicals. Systemic
injury and death can result, however, from some chemicals which pass through the
skin with relative ease. Klaasen (1975) points out that for most materials a large
number of dermal cell layers act as barriers to absorption through the intact skin in
comparison to absorption  through the lung  and gastrointestinal tract,  which
represent only a one- or two-cell layer barrier. Because the intact stratum corneum
represents a major barrier, chemicals that injure this structure may be more rapidly
absorbed.

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                                     41

    Substances present in the lung or gastrointestinal tract have in common the fact
that they are essentially outside the body and produce only localized surface effects
until they are absorbed into the bloodstream. Chemicals absorbed from the lung are
carried directly to the heart and then into the systemic circulation. In contrast, most
compounds absorbed from the gastrointestinal tract are carried directly to the liver,
which in many instances may be a direct target organ. Gastrointestinal absorption, in
contrast to lung absorption, is complicated by several functions of the liver. Because
of its size and enzymatic activity, the liver is the major site of metabolism of most
xenobiotics and is often the target organ of the metabolites formed within its cells. A
variety of chemicals may be excreted through the bile either unchanged or in the form
of metabolites. Once returned to the gastrointestinal tract, these compounds may be
reabsorbed to produce an additional toxic impact on the liver.
    In summary,  the initial  impact  of chemicals absorbed  from  the lung is
considerably different from  effects following  absorption from  the gastrointestinal
tract. Thus the portal of entry may play an important  role in the toxic response,
particularly where  the immediate  organ involved (lung, liver, or skin) is the  target
organ. Target organs different from the portal of entry and exposed strictly from the
systemic circulation  would be expected to respond directly to comparable blood
levels of compound or metabolites regardless of the  route of entry.
    Physico-chemical properties of the chemical may influence the extent of systemic
absorption by various routes of exposure and thereby the  development of the test
procedures. This is discussed in earlier sections.

              5.4  Assumptions and Criteria for Extrapolation

    The following  assumptions were discussed by the committee.

•  Given  quantitative and temporal equivalency  of circulating blood levels of a
   chemical, it is reasonable  to assume that  systemic  effects  will be comparable
   regardless of the route of administration.
•  In making route-to-route extrapolations, only systemic effects other than those
   occurring at the  portal of entry should be considered or compared.
•  Effects at the portal of entry should be considered and evaluated separately.

    When  results of  a subchronic toxicity test are to be considered as definitive, the
committee  recommends  that a study by  the primary human  exposure route be
conducted.  Under  the following conditions, study by  the  primary route is totally
impractical.

• In certain cases the vapor pressure of a compound is low, yet exposure is to the
  vapor. It would be difficult to produce vapor concentrations high enough to induce
  toxicity in animals. Particulate aerosols could be produced, but exposure to these
  would not adequately represent exposure to the vapor. In this case exposure by
  ingestion might be entirely  appropriate.
• Certain industrial dusts are produced in a unique manner (e.g., fiber coating dust in
  making  fibers).  In this  case,  ingestion may  be  the  only  feasible route of
  administration.

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                                     42

• Vapors and organic dusts are possible explosives. While every effort should be
  made to conduct vapor exposures via inhalation, an inhalation study may not
  always be possible. The hazards of dust aerosols could preclude inhalation studies.
• Cost and availability  of compounds may at  times preclude inhalation studies,
  particularly those involving whole body exposure, which are very wasteful of test
  materials, and those using developmental products.

    The Route-to-Route Extrapolation Committee considered the extrapolation of
subchronic data obtained by ingestion of chemicals in the diet to predict effects of
inhalation exposure to be the most  likely to be employed and the most scientifically
acceptable extrapolation. Inhalation-to-ingestion extrapolations are probably feasible
and scientifically reasonable, but will be rarely needed. Extrapolation and estimation
of systemic effects via the inhalation or oral route from data obtained in dermal studies
was considered to be feasible but not very desirable because of a lack of defined
methodology for conducting dermal subchronic studies. Extrapolation to the dermal
route was not considered to be a probable need.
    The validity of any extrapolation should be evaluated when toxic signs developed
in testing by one route indicate that changes might occur in parameters that affect the
absorption, distribution,  metabolism,  etc., by the untested route.
    The committee recognized the  need for separate consideration of extrapolation
criteria to be applied in situations where data are  in existence (retrospective analysis
and extrapolation) and where data are to be developed (prospective analysis and
extrapolation).

               5.5 Retrospective Analysis and Extrapolation

    Retrospective analysis involves the gathering and evaluation of all available data
on the  compound of interest.  The objectives of the analysis are (a) to render a
judgment as to whether the available data are adequate for making an extrapolation
without developing additional data and (b)  to determine what additional data are
needed if existing data are inadequate. In retrospective analyses, the existing data are
likely to range from no data to data from a considerable number of studies that relate
to numerous toxicological responses.
    The following are suggested as guidelines for data evaluation.

• The subchronic study (or studies)  from which data are to be extrapolated must
  have been adequately designed and conducted to allow for proper application of
  extrapolated results. For example, a subchronic study designed and conducted to
  evaluate compound-related effects in only one tissue or organ would  not be
  considered adequate for risk assessment purposes.
• Data from studies  on species  or animal strains different from those used in the
  subchronic study are not acceptable for extrapolation purposes.
• At least one study that assesses compound-related effects at the portal or organ of
  entry by the route to which extrapolation is to  be made is strongly recommended.
• At least one study of the same type and duration (e.g., LD50, LC50, EC50, etc.) and
  utilizing the same end point(s) by each of the two applicable routes of administration
  is essential.

-------
                                     43

• Studies that make route-to-route comparisons of such things as pharmacokinetics
  and metabolism are highly desirable. At a minimum, comparative blood level data
  should be available if any degree of confidence is attached to extrapolated results.
  Data on the other parameters can substantially increase confidence in extrapolated
  results.
• Comparative studies that assess biochemical, hematological, clinical, pathological,
  or other parameters can also increase the degree of confidence.

    Under conditions  when it would  not be practical to perform a study by the
untested route, the procedure presented for prospective analyses is recommended.

                5.6 Prospective Analysis and Extrapolation

    Prospective analysis,  as  envisioned by the  committee, is limited to those
situations in which exposure by the primary route of anticipated human exposure is
impractical and in which either  no  data  exist or existing data are inadequate for
extrapolation purposes.
    In these situations, the investigator  has the advantage  of being able to plan
carefully all studies  involving extrapolation.
    For prospective extrapolations, the committee considers the following as being
representative of ideal requirements:

• data  that  demonstrate  a  similarity in  acute  and/or  subchronic  response(s)
  (including lethality) to the test  material by both routes of administration;
• data that demonstrate equivalency in dose as evidenced by blood levels, total body
  burden, or similar parameters;
• data that reasonably support the conclusion or assumption that pharmacokinetics
  are independent of route of administration;
• data that reasonably support the conclusion that effects at the organ or portal of
  entry by the tested route would or would not be anticipated to occur as a result of
  exposure by the untested route; and
• data that address the possibility of effects at the portal of entry for the untested
  route.

    Given the  knowledge that development of all ideal data will not be feasible, the
committee considers certain combinations of these data to be most desirable.
    The best situation for extrapolation would permit a 14-d study by both routes of
administration. Such a study would serve to establish the target organ(s) and to
demonstrate direct effects on the organ of entry. If the same toxicologic end point
were observed after dosing by both routes, extrapolation from one route to another
after a 90-d study could be carried out with reasonable confidence. In the absence of a
common effect, the concentration of the test material in blood during the 14-d studies
could be used to predict results from an alternative route. The error associated with
this extrapolation would be somewhat greater than in the previous case.
    If 14-d comparisons cannot be performed, comparisons of LD50  data between
each of the routes could be generated. This would serve to equate the doses by the
two routes. However, because the cause of death after acute studies  may not be
related to subchronic toxicity,  this approach would be less desirable.

-------
                                     44

    If  data  comparing toxicity as  a function of route cannot be  obtained, the
extrapolation is more difficult. However, when a need exists, the following information
would be useful:

• physical and chemical properties (solubility in water, acids, saline, octanol-water
  distribution coefficient, particle size in the atmosphere, and pH);
• pulmonary toxicity by intratracheal routes;
• any information on distribution, metabolism, retention, and excretion;
• target organs; and
• in vitro studies.

                      5.7 Summary and Conclusions

• any  extrapolation of toxic dosage levels from one route to another  must be
  considered  in the light of  the associated level of uncertainty. Situations exist
  wherein valid extrapolations cannot be made.
• The justification for extrapolating data rather than performing the subchronic test
  should be based on scientific rationale rather than on  economics alone.
• The literature base for making valid extrapolations is almost nonexistent, although
  much data may exist either in unpublished form or in a form not readily identifiable
  through normal search procedures.
• Most extrapolations would be made using data from  subchronic oral dosing to
  predict inhalation effects, although the reverse may also occur. Some extrapola-
  tions may be made using acute and subchronic dermal studies to predict toxicity by
  other routes, but the reverse is not practical.
• All  available sources  of information should  be sought  out  to minimize the
  uncertainty of such extrapolations. Data from acute, short term, and subchronic
  studies  from all  available routes, human exposure,  and kinetic and  physical-
  chemical input will be needed.
• Extrapolations of this type should be performed by qualified scientists.


6. LIMITATIONS OF ACUTE AND SUBCHRONIC TOXICITY STUDIES

                              6.1  Introduction

    The rationale for the use of the results of toxicity studies in animals and suggested
limitations of these studies are summarized in the following paragraph taken from the
World Health  Organization (1978) document:
       In many cases, studies with laboratory animals make  it possible to predict the
    toxic effects of chemicals in man. However, it is important to realize that experimental
    animal models have their limitations, and that the accuracy  and reliability of a quanti-
    tative prediction of toxicity in man depend on a number of conditions, such as choice
    of animal species, design of the experiments, and methods of extrapolation of animal
    data to man. (p. 35)
    Because there is always some uncertainty in extrapolating the results of toxicity
studies  in animals  to man, a safety  factor is introduced  to compensate for this

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                                      45

uncertainty. The World Health Organization document addressed this  point as
follows:
        In general, the size of the safety factor will depend on (a) the nature of the toxic
    effects, (b) the size and type of population to be protected, and (c) the quality (and
    quantity) of toxicological information available, (p. 38)

                             6.2 Acute Toxicity

    Acute toxicity  studies (oral,  intravenous, dermal, ocular, inhalation,  etc.)
demonstrate biological potency. On this basis an estimate of hazard may be predictive
for a single, accidental human exposure. This extrapolation is not always valid, but
interpretation  of the results may be strengthened by comparison with results for
similar chemicals.

       6.3 Interpretation and Limitations of Acute Toxicity Studies

    The single-dose oral and parenteral (intraperitoneal, intravenous, inhalation,
ocular and/or  dermal) toxicity studies provide a relatively good estimate of the
potential local or systemic toxicity of a single dose to man. The results can help define
the severity and range of toxicity according to dose, species, and sex and may suggest
the need for subchronic tests. The results should include descriptions of the clinical
signs of toxic effects at all dose levels in addition to the determination of the LD50. The
slope of the dose-response curves can be used to estimate safe levels of exposure for
man. A steep  dose curve indicates a relatively narrow range of effect doses,  and
therefore the estimation of the safe exposure level will be more accurate than if there is
a shallow dose-response curve. The shallow dose-response curve, particularly if
toxicity is delayed, suggests a complex biological action of the chemical and therefore
a more variable individual response to the chemical (Casarett  1975).
    The results of these tests give an  indication of the clinical signs of toxicity
produced by the material and may help to determine the potential risk to humans
following oral, dermal, ocular, or inhalation exposure. There are limitations of these
tests that need to be considered when extrapolating to human exposure conditions.
• There are many species-sex variables that make interpretation of the tests difficult.
• Variable results can be produced depending on the vehicles used in the tests.
• High doses  may alter normal  metabolic pathways because of overloading of
  metabolic enzymes and/or exhaustion of substrates required for conjugation.
• Results from single-dose studies are not  reliable for  predicting the  hazards
  associated with continuous low-dose exposure.
• Results from one route of administration may be difficult to  extrapolate to other
  routes.
• Tests  should  still detect  significant  potential  hazard, although  inter-  and
  intralaboratory variation may occur.

    From acute toxicity  studies there are no universal triggers that can be used as
guides to require subchronic studies. The determination of the  need for subchronic
studies should involve not only the magnitude of the dose but also the results of close
observation of the animals.  Delayed  deaths may be the result  of biochemical,

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                                     46

hematologic, or anatomical changes or of persistence of the chemical in the body.
However, these changes may be due to the excessive doses used to produce lethal
effects. If signs of toxicity persist at the end of the observation period of 7 or 14 d,
particularly among animals  at the lower-dose levels, further investigation, including
subchronic studies, may be necessary.

                          6.4  Subchronic Toxicity

    Subchronic  (90-d) toxicity  studies provide a good estimate of a chemical's
potential hazards. These studies reveal essentially the same toxicity pattern (with the
possible exception of ocular and oncogenic effects) as a chronic studies, although the
no-observable-effect dose will be greater than the chronic no-observable-effect dose.
This should be  considered when  evaluating  the hazard  and assessing the risk
associated with the use of the chemical.
    Because extensive  biochemical,  hematological, and  anatomical studies are
included in the subchronic  experiment, certain reactions may trigger the need for
additional studies. Also, because the dose range used  in  the subchronic  studies
includes  both  toxic and nontoxic doses, there inevitably will be changes in one or
more of the large number of laboratory tests used as well as in the pathology studies.
These changes must be evaluated  carefully. Only if they occurred with increasing
severity from the low-dose level to  the high-dose level should  additional studies be
considered. Examples of such triggers are hyperglycemia, particularly with changes of
the beta cells of the pancreatic islets; alternation of the differential white cell count,
particularly if a neutropenia is evident; decreased testicular weight, particularly with a
decrease in the number of sperm; and unusual hyperplastic change beyond that which
could be expected as a physiological alteration.
    Conventional subchronic studies are of limited value in defining potential adverse
effects on the areas of behavior, species  variation, reproductive physiology, and
immunotoxicology. Furthermore, the conventional subchronic study is of virtually no
value in  defining  potentially adverse effects in the areas of teratogenesis,  genetic
effects, longevity, and neoplasia.

                        6.5 Special Considerations

6.5.1 Reproduction and teratology
    Changes  in  reproductive  tissues as  determined in subchronic studies  may
suggest the need for fertility and/or reproduction  studies.  The selection of the
maximum dose for teratology studies is critical, because a maternal toxic dose may
indirectly cause fetal malformations. Therefore, teratology studies should be done
only after completion of subchronic studies.

6.5.2 Recovery
    Recovery studies may be needed to determine if an adversely affected parameter
returns to normal after termination of exposure. The lack of recovery at low doses
may dictate the need for additional long-term studies usually at the same and lower
dose levels.

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                                     47
6.5.3 Pharmacokinetic and metabolic data

     One has  to make a judgment about the  need for  pharmacokinetic and/or
metabolic data. These data can be used to facilitate or clarify human risk assessment
or to select the appropriate species for subchronic studies. In this instance, studies of
absorption, distribution, metabolism, and elimination (ADME) on pertinent species
with particular emphasis on biologic half-life may be appropriate. In specific cases,
pharmacokinetic studies, including the identification of important metabolites, may be
appropriate. The need for metabolic studies should be determined by sound scientific
judgment based on the expected exposure of humans and the degree and extent of
toxicity observed in animals.
     It is clear that there are scientific and economic bases  for deciding what species
will be used. From a scientific reference point, one would recommend the use of that
species for which the ADME is most like that of the human (if this can be deduced).
The economic bases for selecting species, cost and availability, may influence the
decision.

                      6.6 Dermal and Ocular Studies

     In the industrial situation, unless adequate protection is provided, the most likely
exposure to chemicals (excluding inhalation)  is by dermal and/or ocular exposure.
Dermal exposure  is particularly important because of the potential  for systemic
exposure by penetration of the chemical through the skin. Although the rabbit is the
most frequently used species, its skin is more permeable than human skin for most
compounds (Bartek, La  Budde, and Maibach  1972). The  animals  in  which
characteristics of cutaneous penetration most resemble those in the human are the
rhesus monkey and the domestic swine (Wester and Maibach 1977). Other aspects of
potential toxicity due to dermal exposure are irritation (Mathias and Maibach 1978),
contact sensitization (Magnusson and Kligman 1977; Marzulli and Maibach  1977),
phototoxicity (Maibach and Marzulli 1977), photoallergy (Harber and Shalita 1977),
hypopigmentation  or hyperpigmentation  (Gellin, Ring, and Maibach 1977),  and
chloracne (National Academy of Sciences 1977). In these various tests, extrapolation
to the human requires consideration of species, site of application, dose, vehicle, and
method  of  application. Some  of the limitations  of dermal studies that  affect
extrapolations are  as follows:
•  Rabbit skin is more permeable than human skin for most compounds.
•  Manyfold differences in permeability occur from the least to the most permeable
   anatomic sites.
•  Nonperspiring rodent or rabbit skin does not directly mimic human skin.
•  Sufficient information is often unavailable for extrapolating from the mouse, guinea
   pig, hamster, or  dog to the  human.
•  Use of occlusive dressings on test animals exaggerates human exposure.
•  Duration of exposure (i.e., 24 h) in test animals exaggerates human exposure (i.e., 8
   h/d).

    Eye irritation tests (Draize 1959) give an index of eye irritation potential in the
absence of human exposure. These tests should be used for comparison with groups

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                                    48

of closely related compounds for which human data are available. In the rabbit test a
positive result should be assessed along with other factors affecting human exposure
such as conditions of use and misuse. When the test results in the rabbit suggest
potential hazard, tests in the rhesus monkey may  be useful as an aid to evaluate
hazard for humans (Buehler and Newman 1964; Beckley, Russel, and Rubin 1969).

                             6.7 Conclusions

    Valuable information for assessing the risk of a chemical can be obtained from
acute and subchronic studies in animals. The doses used in such studies (nontoxic to
toxic levels) and the duration of the subchronic study (about 90 d), with a wide variety
of laboratory tests and ultimately pathology, provide a good evaluation of the
toxicologic attributes of that chemical and  may also determine whether additional
studies are necessary. Almost invariably acute systemic toxicity studies would also be
available if a subchronic study is to be done, because the need for a subchronic study
is usually indicated by the results of an acute study, which is also necessary to permit a
more scientific selection of dose levels for the subchronic study. Once the toxicologic
attributes of a chemical are known, certain risk evaluations can be made on the basis
of the type of toxicity and the possible exposure of humans. Acute toxicity studies by
themselves can be of some value, particularly for single exposure for the human, but
they are unreliable for more than a suggestive risk if continued exposure is probable.
The dermal and ocular acute tests again are useful for very short-term exposure that
most likely would occur in the use of the chemicals. However, single dermal exposure
would be of little, if any, value for the determination of systemic toxicity unless
penetration is so rapid  that substantial blood levels are obtained with consequent
potential toxic effects.


               7. UNRESOLVED ISSUES AND RESEARCH
                         RECOMMENDATIONS

    The committees identified the issues and research needs associated with
subchronic testing. The issues identified are the ones that could not be resolved
because of a lack of literature and time. The committees were to recommend the
appropriate research solutions for these areas and  issues. They are as follows:

                          7.1 Unresolved issues

1. The use of nonrodent test species: Available literature  should be reviewed to
   determine whether nonrodent species reveal unique or different signs of toxicity
   with sufficient frequency to warrant their routine use. This would include published
   information and data solicited by  a  general appeal to academic institutions,
   governmental agencies, and industrial concerns.
2. Duration for dog studies: It is recommended that comparisons of the literature data
   from dog studies in three-month and two-year durations can and should be made. If
   the former adequately predict the latter, the dog should be included as a species in
   the subchronic studies and not in nononcogenic chronic studies.
3. Number  of animals: The exact  number of test animals and the  associated
   appropriate statistical treatments  should be evaluated.

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                                      49

 4. Relationship between chemical class and toxic effect: A data base needs to be
   generated that will aid in the correlation of specific tissue effects with chemical
   structure and activity. This will aid the prediction of toxic effects and assist the
   investigator in the protocol design for specific chemicals. Also, it would be useful to
   include similar information on chemical classes and organ systems.
 5. Extrapolations from route to route (factors affecting the feasibility):
   a. An in-depth review of the literature should be undertaken to find data where the
      same chemical has been evaluated by different routes of exposures. This review
      should include acute, subchronic, and chronic data.
   b. A critical evaluation of such available data should be undertaken to establish for
      specific materials, or classes of compounds, whether target organs and overall
      animal response are comparable by the two routes.
   c. If variable dose and quantitative response data are available, a reasonable basis
      for extrapolation may be developed for individual materials and possibly groups
      of  chemical compounds.

                     7.2 Research Recommendations
 1. Comparative experimental studies of 14-, 30-, and 90-d durations are needed to
   evaluate  the usefulness of  the shorter period.  These studies  could include
   comparisons of various arrangements  of toxicity  parameters  (e.g.,  enzyme
   function tests, hematology tests, pathology) that would help determine the
   appropriate tests necessary for the different durations.
 2. Research is needed to determine the applicability of pharmacokinetic methods to
   the development of models  for interspecies extrapolation.  Differences  in the
   responses of species to specific chemicals can be related to  differences of half-
   lives of the parent compounds or toxic  metabolites.  In addition, the  route of
   elimination can vary  between species with an increase of toxicity resulting in
   specific organs of elimination in one species and not another. Pharmacokinetic
   methodology could also reveal the overloading of enzyme systems that may be
   deficient in one species as compared to  another.
 3. The similar metabolism of a compound in  animal species suggests that their
   biological responses to toxic chemicals may be similar. Therefore, a rapid in vitro
   metabolic experiment using microsomal  enzyme preparations from the liver or
   other  indicated organs from several animals, including man, may aid  in the
   selection of the most suitable animal for  subchronic experiments. A data base
   should be compiled that lists known differences in biological  response between
   species, including humans, and correlates  these with species  differences in
   ADME.
4. To evaluate the potential use of oral studies to determine inhalation effects, acute,
   two week, and subchronic 90-d studies  should be performed by both routes.
   Included in these studies  should be pharmacokinetic data to  ascertain the
   development of steady state blood levels and tissue distribution. Histopathologi-
   cal data should be obtained on both short-term and subchronic studies. These
   data should be used to demonstrate the validity of extrapolation from one route
   to another and to develop extrapolation  factors.
5. Research is needed  to  determine the  degree of species specificity for the
   functional and biochemical tests. Because these tests  were  originally used for

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                                     50

    diagnosis of human diseases, their applicability to different test species and organ
    function interpretation should be evaluated.
 6.  The value and utility of reversibility studies in a subchronic protocol design needs
    to be determined, utilizing data from existing literature for many chemical classes.
 7.  The evaluation of electroencephalograms in dogs is only a relatively recent art,
    and insufficient information is available to allow accurate evaluation. Future
    research in this area would serve to rapidly increase the store of knowledge for
    this potentially important toxicologic criterion.
 8.  Methodology for evaluation of audio toxicity  should be developed.
 9.  Methodologies should be developed for evaluating memory and learning and their
    interpretation.  Because of the increasing number of chemicals  that could
    potentially affect the higher centers and because of the subtlety of such effects,
    techniques to detect early and minor alterations in memory and learning ability
    need to be developed and applied on a practical and routine basis.
10.  Experimental research is needed to correlate induced sedation and aggressive-
    ness with changes in the central nervous system. The changes in the central
    nervous system could be either anatomical (destruction of specific areas in the
    brain) or changes in the production of chemicals that affect the nerve conduction
    and synaptic end points. Little attention has  been paid to the central nervous
    system effects during the administration of a chemical, and sedation or other
    effects have  been accepted without consideration of the mechanism involved,
    except in the case of pathological lesions.
11.  Testing  and assessment procedures  for  cardiovascular toxicity  should  be
    developed, particularly in regard to the causative chemical classes of compounds.
12.  The mechanisms  of intrahepatic cholestasis  and its relationship with hepatic
    damage should be studied. This  is especially important, because this effect
    cannot  be predicted  accurately  by animal  studies  and because  it occurs
    frequently in humans.
13.  Immunotoxicology methods need to  be developed  and evaluated for their
    potential utility. At the present time, immunology is in the stage of basic research.
    Such basic research does not always provide the practical methods necessary for
    toxicology. An adequate basic group of immunologic techniques should be
    developed that will highlight potential adverse  effects on the immune system and
    thus trigger  the need for further studies.
14.  Chemically induced hyperplastic changes in the mammary gland, urinary bladder,
    and liver need to be studied to determine their relative significance. Because
    these organs, particularly the mammary gland and the liver, respond to various
    physiological stimuli, cellular activity varies within the wide normal limits. The
    point at which normal hyperplasia becomes abnormal is difficult to determine but
    is important relative  to evaluating whether  a specific change is approaching
    preneoplastic or neoplastic transformation. These hyperplastic changes need to
    be studied under specific highly controlled conditions in order to develop criteria
    that will permit a better evaluation of cellular changes as related to the detection
    of carcinogens.
15.  The  influence  of  chemical  exposure  upon spontaneous  disease,  such as
    nonspecific  pneumonitis, should be determined. This type  of  drug effect is

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                                51

important not only in the conduct of toxicology studies, but also as regards the
potential activity of the chemical during exposure of man. Occasionally during
subchronic and chronic toxicity studies, a chemical may appear to affect the
incidence or severity of spontaneous diseases. However, the incidence and
severity of spontaneous disease can vary considerably in animals so that a
determination of chemical effect becomes difficult.

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                  APPENDIX

      COMMITTEES AND PARTICIPANTS

          Keynote speaker: Warren Muir

              Experimental Design

              Emil Pfitzer, Chairman

James Allen                     Bernard McNamara
Domingo Aviado                 Norbert Page
Kenneth Back                   Joseph  Seifter
George Levinskas                Carrol Weil

        Relationship of Test Design and
            Chemical Classification

          Clarence J. Terhaar, Chairman

Sidney Green                   Peter Voytek
Elliott Harris                    HanspeterWitschi
Victor Morgenroth III             Paul Wright
Marshall Steinberg

       Clinical Evaluations and Pathology

           Frederick Oehme, Chairman

Diane Beal                      Donald  McGavin
Jerry Kaneko                   Bobby Joe Payne
Charles Litterst                  Zophia Zawidzka

       Extrapolation from Route to Route

              Bob Gibson, Chairman

Werner Braun                   Arthur McCreesh
Herbert Cornish                 Daljit Sawhney
Robert Drew

       Limitations of Subchronic Studies

             Harold Peck, Chairman

James Emerson                  Ted Loomis
Wayne Galbraith                 Howard Maibach
Charles Kokoski                 Carl Smith
                       53

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                       54
              Steering Committee

Wayne Galbraith                 Emil Pfitzer
Bob Gibson                     Clarence J. Terhaar
Frederick Oehme                Michael Ryon
Norbert Page                    Daljit Sawhney
Harold Peck

              ORNL Support Staff

Norma Callaham                 Robert Ross
J. Tim Ensminger                Michael Ryon
Pat Hartman                    Donna Stokes

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                                       55
                                  Participants
James R. Allen, D.V.M., Ph.D
Department of Pathology
University of Wisconsin
470 North Chaute' Street
Madison, Wisconsin 53706
(608) 263-3524

Domingo Aviado, M.D.
President, Atmospheric Health Sciences,
  Inc.
P.O. Box 307
Short Hills, New Jersey 07078
(201) 379-3141

Kenneth C. Back, Ph.D.
Toxicology Branch
Air Force Aerospace Medical Research
  Laboratory/ (THT)
Wright-Patterson Air Force Base, Ohio
  45433
(FTS) 755-5257

Diane Beal, Ph.D.
Office of Pesticides and Toxic
  Substances
Health Review Division—TS/792
Environmental Protection Agency
401 M Street, East Tower
Washington, D.C. 20460
(202) 755-2890

Werner  Braun, M.S.
Dow Chemical USA
1803 Building
Midland, Michigan 48640
(517) 636-6151

Herbert  H. Cornish, Ph.D.
Department of Environmental and
  Industrial Health
University of Michigan
M7525 School of Public Health
Ann Arbor, Michigan 48109
(313) 764-5430

Robert T.  Drew, Ph.D.
Medical  Department
Brookhaven National Laboratory
Upton, Long Island, New York 11973
(516) 345-3575
James Emerson, D.V.M., Ph.D.*
Manager, Department of Pathology
Abbott Laboratories D469 AP
N. Chicago, Illinois 60064
"Current address:
Manager, Life Sciences
The Coca Cola Company
P.O. Drawer 1734
Atlanta, Georgia 30301


J. Tim Ensminger, M.S.
Health and Environmental Studies
   Program
Information Center Complex
Oak Ridge National Laboratory
P.O. Box X, Building 2001
Oak Ridge, Tennessee 37830
(615) 574-7794
Wayne Galbraith, Ph.D.
Office of Research and
  Development—RD683
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
(202) 426-2317


James R. Gibson, Ph.D.
E. I. Dupont de Nemours & Co.
Haskell Laboratory for Toxicology and
  Industrial Medicine
Newark, Delaware 19711
(302) 366-5257


Sidney Green, Ph.D.
Bureau of Foods
Food and Drug Administration
200 C Street, S.W.
Washington, D.C. 20204
(301) 245-62%


Elliott Harris, Ph.D.
National Institute for Occupational Safety
  and Health
4676 Columbia Park
Cincinnati, Ohio 45226
(513) 684-8465

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                                       56
Jerry Kaneko, D.V.M., Ph.D.
Department of Clinical Pathology
School of Veterinary Medicine
University of California
Davis, California 95616
(916) 752-0153

Charles J. Kokoski, Ph.D.
Chief of Food Additives Evaluation
  Branch
Division of Toxicology
Food and Drug Administration
N. HEW Bldg. 3075
Washington, D.C. 20204
(202) 472-5767

George J. Levinskas, Ph.D.
Director of Environmental Assessment
  and Toxicology
Department of Medicine and
  Environmental Health
Monsanto Company
800 North Lindbergh Boulevard
St. Louis, Missouri 63166
(314) 694-2184
Charles Litterst, Ph.D.
Laboratory of Toxicology
National Cancer Institute
Bldg. 37, Room 5B-22
Bethesda,  Maryland 20205
(301) 496-6713

Ted A. Loomis, Ph.D., M.D.
Department of Pharmacology
University of Washington
School of Medicine
Seattle, Washington 98195
(206) 543-0169

Howard I.  Maibach, M.D.
Department of Dermatology
University of California Medical Center
San Francisco, California 94143
(415) 666-2545
(415) 673-9693
Arthur McCreesh, Ph.D.
Toxicology Division
U.S. Arrny Environmental Hygiene
  Laboratory
Aberdeen, Maryland 21010
(301) 671-3627

M. Donald McGavin, D.V.M., Ph.D.
Department of Pathobiology
University of Tennessee
College of Veterinary Medicine
P.O. Box 1071
Knoxville, Tennessee 37901
(615) 546-9230

Bernard McNamara, Ph.D.
Chief, Toxicology Branch
Research Division
Chemical Systems Laboratory
Aberdeen Proving Ground, Maryland
  21010
(501) 671-3034

Victor H. Morgenroth III, Ph.D.
Food Additives Evaluation Branch
Division of Toxicology
Bureau of Foods
Food and Drug Administration HFF/185
N. HEW Bldg. 3075
Washington, D.C. 20204
(202) 472-5705

Warren R. Muir,  Ph.D.
Deputy Assistant Administrator
Office oi Pesticides and Toxic
  Substances
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
(202) 755-4894

Frederick Oehme, D.V.M., Ph.D.
Comparative Toxicology Laboratory
College of Veterinary Medicine
Kansas State University
Manhattan, Kansas 66506
(913) 532-5679

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                                        57
Norbert P. Page, D.V.M.
Director of Scientific Affairs
Environmental Protection Agency
  (TS-792)
401 M Street, SW
Washington, D.C. 20460
(202) 755-4894

Bobby Joe Payne, D.V.M., Ph.D.
Director of Pathology
Toxicity Research Ltd.
510 West Hackley Avenue
Muskegon, Michigan 49444
(616) 733-2584

Harold Peck, M.D.
Safety Assessment Department
Merck, Sharp & Dohme Research
  Laboratories
West  Point, Pennsylvania  19486
(215) 699-5311

Emil Pfitzer, Ph.D.
Hoffman-LaRoche, Inc.
Experimental Pathology and Toxicology
Nutley, New Jersey 07110
(201)-235-3028

Robert H. Ross, B.S., M.S.
Health and Environmental Studies
  Program
Information Center Complex
Oak Ridge National Laboratory
P.O. Box X, Building 2001
Oak Ridge, Tennessee 37830
(615) 574-7797

Michael G. Ryon, B.S.
Health and Environmental Studies
  Program
Information Center Complex
Oak Ridge National Laboratory
P.O. Box X, Building 2001
Oak Ridge, Tennessee 37830
(615) 576-2378
Daljit Sawhney, D.V.M., Ph.D.
Environmental Protection Agency
  (TS-792)
401 M Street, SW
Washington, D.C. 20460
(202) 755-4864
Joseph Seifter, M.D.
Senior Medical Officer
Office of Testing and Evaluation
Office of Pesticides and Toxic
  Substances
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
(202) 755-4894

Carl C.  Smith, Ph.D.
Department of Environmental Health
University of Cincinnati
3223 Eden Avenue
Cincinnati, Ohio 45267
(513) 872-5745

Marshall Steinberg, Ph.D.
Vice President and Director of Scientific
  Operations
Hazleton Laboratories America, Inc.
9200 Leesburg Turnpike
Vienna,  Virginia 22180
(703) 893-5400

Clarence J. Terhaar, Ph.D.
Eastman Kodak Company
Kodak Park—B306
Rochester, New York 14650
(716) 458-1000 ext. 84741

Peter Voytek, Ph.D.
Office of Research and Development
Reproductive Effects Assessment Group,
  RD689
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
(202) 426-2275

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                                        58
Carrol S. Weil, M.A.
Mellon Institute
4400 Fifth Avenue
Pittsburgh, Pennsylvania 15213
(412) 327-1020

Hanspeter Witschi, M.D.
Biology Division
Oak Ridge National Laboratory
P.O. Box Y, Buildng 9207
Oak Ridge, Tennessee 37830
(615) 574-0801

Paul L. Wright, Ph.D.
Monsanto Company
800 North Lindburg
St. Louis, Missouri 63166
(314) 694-2196

Zophia Zawidzka
Toxicology Research Division
Health Protection Branch
Sir Frederick Banting Building
Health and Welfare Canada
Ottawa, Ontario
Canada K1A OL2
(613) 995-5874

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                                       61

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                                                 63
 REPORT  DOCUMENTATION .' REPORT NO                      I 2.
 	PAGE	L_EP/L560/lb80_-028	|	
 4  rule and Subtitle
              Proceedings of  the  Workshop  on  Subchronic Toxicity
              Testing.   Denver, Colorado, May 20-24, 1979.
                                                                        3. Recipient'! Acce»»ion No
                                                                       s. BwToiu        date "oT"
                                                                        November, 1980   issue
                        jiawhney,  OPTS^ and Michael  G. Ry_on_,
          Organization Name end AddnKt
             Information  Center Complex
             Information  Division
             Oak Ridge National Laboratory
             Oak Ridge, TN  37830
                                                                       8, P*rformmf Organization Rept

                                                                        ORNL/EIS-189
                                                                       10 Project/Te$k/Work Unit No


                                                                       11 Contract(C) or Grant(G) No

                                                                       (c, IAG-80-D-X0453
 12. sponsoring Organization Name and Address
             Office of  Pesticides  and Toxic Substances
             U.S. Environmental  Protection Agency
             Uashington,  D.C.  20460
                                                                       13 Type of Report & Pvriod Covcrtd


                                                                          Final
 1C. AMtrict (Lin
                   This  workshop  was held at  Denver, Colorado, May 20-24,  1979,
              to assist  the Office  of Pesticides  and Toxic  Substances  in developing guide-
              lines  for  Subchronic  toxicity testing under the  Toxic Substances Control
              Act.   The  participants were organized into committees to  discuss the
              relationship of protocol  design  to  chemical class, the experimental design
              (route  of  exposure, dose, duration,  test species,  and acie and  nunber of
              animals),  the evaluation of toxic effects (clinical  observations, clinical
              laboratory tests, and pathology), the criteria for data  extrapolation from
              one route  of administration to  another route, and  limitations  of acute
              and Subchronic tests.  Research  recommendations  Submitted by each committee
              for their  topic areas are presented  in the document.
17. Document Analy*,*  •  Detcnpton  QOS3Q6
                          Time
                          Extrapolation
                          Methodology
                                              Tests
                                              Pathology
                                              Laboratory animals
                                              Subchronic Toxicitv
                                                                           Health
   b Identifier*/Open Ended Tern
   c COSATI n*td/Gn>up
                           EPA Denver Workshop
                           Subchronic Toxicity Workshop
                           06/T
It. Availability Statement


             Release Unlirmtel
Tl9. Security Cr«» (Thi* Report)


I 20. Security Cl»*t (Tr.it P«f«)
!   Unclassified
                                                                                   21 No I

                                                                                     65
(Se« ANSI-239 II)
                                         See instruction* on Reverse
                                                                                  OPTIONAL FORM 272 (4-77)
                                                                                  (Formerly NT1S-35)
                                                                                  Department of Commerce
                                                         <*U S GOVERNMENT PRINTING OFFICE  1980 740 062/373

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